This Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy ("Policy") is adopted by the Company operating the Platform. The Company is committed to preventing money laundering, terrorist financing, and other financial crimes. This Policy applies to all users of the Platform, employees, contractors, and any third parties acting on behalf of the Company. The Company operates under the laws of Curaçao and adheres to international AML/CTF standards, including the recommendations of the Financial Action Task Force (FATF).

The Company has a zero-tolerance policy towards money laundering and terrorist financing. We are committed to: • Complying with all applicable AML and CTF laws and regulations • Implementing robust customer due diligence (CDD) and enhanced due diligence (EDD) procedures • Monitoring transactions for suspicious activity • Reporting suspicious transactions to the relevant Financial Intelligence Unit (FIU) • Maintaining comprehensive records • Training our staff on AML/CTF obligations • Cooperating fully with law enforcement and regulatory authorities We will not engage in business with any person or entity that we know or suspect is involved in money laundering, terrorist financing, or other illicit activity. We reserve the right to refuse service, suspend accounts, or terminate relationships where we have concerns about AML/CTF compliance.

For the purposes of this Policy: "Beneficial Owner" means the natural person(s) who ultimately owns or controls a customer or the natural person on whose behalf a transaction is being conducted. "Customer Due Diligence (CDD)" means the process of identifying and verifying the identity of a customer and assessing the risk associated with the business relationship. "Enhanced Due Diligence (EDD)" means additional measures applied in higher-risk situations. "Financial Intelligence Unit (FIU)" means the national body responsible for receiving, analyzing, and disseminating suspicious transaction reports. "Money Laundering" means the process of concealing the illegal origin of proceeds of crime. "Politically Exposed Person (PEP)" means a natural person who is or has been entrusted with a prominent public function, or a close associate or family member of such person. "Suspicious Activity" means any transaction or pattern of transactions that gives rise to a reasonable suspicion of money laundering or terrorist financing. "Terrorist Financing" means the provision or collection of funds with the intention or knowledge that they will be used to carry out terrorist acts.

The Company has appointed a designated Money Laundering Reporting Officer (MLRO) responsible for overseeing AML/CTF compliance. The MLRO has sufficient authority and resources to implement this Policy effectively. The Board of Directors receives regular reports on AML/CTF matters and ensures adequate oversight. The Policy is reviewed and updated periodically to reflect changes in laws, regulations, and best practices. All employees and contractors with access to customer or transaction data receive AML/CTF training appropriate to their role.

A. Customer Identification and Verification Before allowing a customer to deposit, withdraw, or use our services, we conduct Customer Due Diligence (CDD). We collect and verify: • Full legal name • Date of birth • Residential address • Nationality and country of residence • Government-issued identification document • Proof of address (e.g., utility bill, bank statement) • For corporate customers: company registration documents, beneficial ownership information, and authorized signatories We use reliable, independent sources to verify identity. Where we cannot satisfactorily verify identity, we do not establish or continue the business relationship. For higher-risk customers, we apply Enhanced Due Diligence (EDD), which may include: • Obtaining additional documentation • Understanding the source of funds and source of wealth • Obtaining senior management approval • Conducting ongoing monitoring more frequently Politically Exposed Persons (PEPs) and their close associates are subject to EDD. We assess the risk associated with each customer and apply controls proportionate to that risk. B. Ongoing Monitoring We conduct ongoing monitoring of business relationships. This includes: • Scrutinizing transactions throughout the relationship to ensure they are consistent with our knowledge of the customer • Keeping customer identification data up to date • Regularly reviewing high-risk and PEP relationships • Identifying and investigating unusual or suspicious patterns We use automated systems and manual reviews to monitor transactions. Thresholds and rules are configured based on regulatory requirements and our risk assessment. C. Transaction Monitoring We monitor transactions for indicators of money laundering and terrorist financing, including: • Transactions inconsistent with the customer's profile or stated purpose • Structuring (breaking transactions into smaller amounts to avoid reporting thresholds) • Rapid movement of funds (layering) • Use of the platform in a manner inconsistent with its intended use • Transactions involving high-risk jurisdictions • Unusual patterns of deposits and withdrawals • Use of multiple accounts or payment methods without clear explanation Where we identify suspicious activity, we conduct an investigation, document our findings, and where appropriate, file a suspicious transaction report (STR) with the relevant FIU. We do not tip off the customer that a report has been made. D. Record Keeping We maintain records of: • Customer identification and verification documents • Transaction records • Results of CDD and EDD • Internal suspicious activity reports and STRs • MLRO decisions and rationale • Training materials and attendance records Records are retained for at least five years from the date of the end of the business relationship or the date of the transaction, as required by applicable law. Records are stored securely and are accessible to authorized personnel and regulators.

All employees and relevant contractors receive AML/CTF training upon joining and periodically thereafter. Training covers: • Relevant laws and regulations • This Policy and internal procedures • Red flags and indicators of suspicious activity • How to report suspicious activity • Consequences of non-compliance Training is documented, and comprehension is assessed. The MLRO ensures that training materials are kept up to date and that staff in high-risk roles receive enhanced training.

Where the MLRO determines that a transaction or pattern of activity is suspicious and may relate to money laundering or terrorist financing, the Company will file a Suspicious Transaction Report (STR) with the relevant Financial Intelligence Unit without delay. We will not inform the customer or any third party that a report has been filed, as tipping off is an offence. We will cooperate fully with law enforcement and regulatory authorities in connection with any investigation. We will not provide services or proceed with transactions where we have filed or intend to file an STR, until we have received appropriate guidance from the FIU or other competent authority.