1. Objectives
Anti-Money Laundering (AML) / Counter-Terrorism Financing (CFT) is the process of concealing financial transactions to make illicit money generated from illegal activities, such as money laundering, corruption, illegal gambling, terrorism, and organized crime, appear legitimate. Money laundering typically follows three stages:

• Placement – the physical handling of funds derived from criminal activity.
• Layering – separating illicit funds from their source by creating complex layers of financial operations designed to obscure the audit trail and ensure anonymity.
• Integration – making the illicit funds appear legitimate, allowing them to re-enter the economy as normal business funds.

The primary goal of AML is to conceal the true origin of illicit funds and render them legally usable through a series of financial transactions. Technological advancements have allowed money launderers to transfer funds across borders faster, making detection and prevention much harder. The abuse of the financial system for fraudulent purposes has become a global issue, one that requires dynamic solutions at all levels.
As a responsible entity, we believe it is our moral, social, and economic duty to prevent the misuse of the financial system to launder proceeds from criminal activities and to participate in the global fight against money laundering. Our role in combating criminal activity starts with the "Know Your Customer" (KYC) principle.
Understanding the determination of the international financial community to fight money laundering, our company has committed to conducting business honestly and diligently, aiming to ensure compliance with applicable laws, regulations, and practices. The aim of AML / KYC / CFT measures is to prevent the use of the company’s systems for money laundering or terrorism financing. Therefore, our AML / KYC / CFT measures include:

1. Customer Identification Procedure – the "Know Your Customer" (KYC) process.
2. Monitoring of suspicious transactions.
3. Designating a Compliance Function.
4. Employee training.
5. Maintaining documentation.
6. Testing the implementation of AML / KYC / CFT and compliance measures.

Due Diligence Procedures (CDD) include:
(a) Identification of the customer.
(b) Determining whether the customer is acting on behalf of a third party, and identifying the third party.
(c) Verifying the identity of the customer and any third party on whose behalf the customer is acting.
These procedures apply to all branches, offices, contractors, and associated companies and should be read in conjunction with related operational guidelines issued from time to time.
The responsibilities of management and employees include:

• Developing and implementing policies, procedures, and controls related to the acceptance, maintenance, and monitoring of customers.
• Conducting due diligence on customers.
• Refusing or terminating business relationships or transactions.
• Training personnel on customer acceptance, maintenance, and monitoring.
• Monitoring accounts, activities, policies, procedures, and plans.
• Ensuring awareness and communication.
• Management reporting.
• Reporting suspicious activities (SAR/STR) to the Financial Intelligence Unit (FIU).

Basic Principles and Objectives:
This guide sets forth the following core principles and objectives:

• The company will implement the necessary policies and procedures to mitigate the risk of potential money laundering, terrorism financing, or related activities.
• The customer due diligence procedures will be developed and implemented in accordance with applicable law.
• To establish a business relationship with a potential client, appropriate information will be obtained from the individual wishing to establish the relationship.
• The obtained information will be verified by comparing it with information from sources as required by law.
• The company may refuse or terminate business relationships or transactions if there is a risk that its services or infrastructure may be used for money laundering or terrorism financing.
• The company will train all relevant employees regarding customer acceptance, maintenance, and monitoring.
• The company will actively monitor compliance with this procedure to ensure it is performed in accordance with the law.
• Employees should familiarize themselves with this guide, including their duties and expected actions.
• To effectively monitor customer acceptance, maintenance, and monitoring, management reports will be maintained.

2. Compliance Function
The company's compliance function consists of two levels and includes responsibilities for anti-money laundering specialists and specialists responsible for ensuring compliance with money laundering regulations.

1. The CEO (also responsible for anti-money laundering) and the Board of Directors.

The CEO’s and Board’s Responsibilities:

• Establishing a culture within the company that supports achieving compliance goals by ensuring rigorous selection, screening, development, and monitoring of staff who meet the requirements.
• Promoting awareness among all levels of staff about the importance of adhering to AML / CFT and KYC procedures.
• Overseeing the development, continuous updating, and implementation of compliance policies and procedures.
• Working closely with the Compliance Department to ensure effective communication between the Compliance Department and the Board.

1. The Compliance Department, led by the Chief Operating Officer (who acts as the money laundering compliance specialist).

The Compliance Officer's Responsibilities:

• Designating staff responsible for compliance (Compliance Department personnel).
• Monitoring, coordinating, and controlling the daily operations of compliance specialists.
• Training compliance specialists.
• Reporting to the CEO and Board if the Compliance Department suspects a transaction may lead to money laundering.
• Overseeing the implementation of AML / KYC / CFT measures and compliance procedures.
• Reviewing and updating this guide.

Responsibilities of the Compliance Department:

• Conducting necessary checks to detect suspicious transactions.
• Cancelling or prohibiting transactions.
• Receiving disclosures related to suspicious transactions from staff or other sources.
• Training personnel and preparing detailed guidelines to detect suspicious transactions.

3. "Know Your Customer" (KYC) Procedures
All transactions should only proceed after proper identification of the customer.
Customer identification is a critical element of KYC standards.
The company follows a systematic procedure for identifying new customers and cannot establish business relationships until the identity of the new customer has been satisfactorily verified.
The company must obtain and verify relevant customer information to establish their identity and the purpose of the business relationship.
The required scope and nature of this information depend on the entity applying (individual, corporate, etc.) and the expected transaction size.
The company will review all client records periodically to ensure that the data remains current. If, however, the Compliance Department determines that insufficient information exists about a client, it will immediately take steps to obtain the missing data as quickly as possible.
If issues arise with verifying a client, and these cannot be resolved, the company may close the account and refund the funds to the original source.
The company will not allow business relationships with customers who wish to remain anonymous or provide fictitious names.
Client Acceptance Policy
Customer security is paramount to our company. We are committed to protecting the interests of our clients by adhering to best practices to ensure the security of their personal data and to prevent fraud, money laundering, and terrorist activities.
Our KYC procedures are rigorous, ensuring that every client is properly identified, and transactions are secure. Clients must follow these procedures for their investment activities to be valid, and without completing them, you will not be able to withdraw funds or conduct business.
The documents required for account registration and funding include:

• Proof of identity (valid for at least 6 months):
• Passport
• ID card
• Driver’s license
• Proof of address (no older than 3 months):
• Utility bill
• Bank statement
• Official certificate
• Invoice, etc.

If documents are not submitted, restrictions will be applied to the account, and withdrawal requests will be blocked.
Withdrawal Requests
The company allows clients to withdraw funds at any time, subject to compliance with the conditions outlined for bonuses and promotions.

• A signed withdrawal request form must be submitted.
• Withdrawals are made to the same account from which funds were deposited (bank transfer, credit card, etc.).

Compliance procedures for withdrawal requests are as follows:

• Client submits withdrawal form.
• Client identification is verified.
• Compliance verification of the transaction and withdrawal method.

If any suspicious activity is identified, it must be reported to the Compliance Department before executing the transaction.