Counter-Terrorism Financing Policy

AI Crypto Market prohibits any involvement in the financing of terrorism, including the compilation of weapons or for the use of nuclear, chemical or biological weapons and their means of delivery and related materials (including both technologies and dual-use goods used for non-legitimate purposes), that contravenes any laws of the USA.

In order for terrorists and terrorist organizations to acquire weapons of mass destruction, they must possess adequate funds and access to financial services for purchasing such weaponry. AI Crypto Market is responsible for ensuring that its business operations, services are not misused by terrorists and terrorist organizations to funnel funds to weapons suppliers.

Hence, AI Crypto Market ensures that its CTF program is robust, comprehensive, and efficient in identifying and reporting proliferation financing to the appropriate supervisory authority in compliance with relevant legal statutes.

As a digital asset services provider, AI Crypto Market acknowledges the existence of Terrorism Financing (TF) risks, which could potentially involve its services and products in facilitating money laundering or terrorist financing schemes. Alongside the regulatory risks of non-compliance with legislation, these TF risks may impact AI Crypto Market's business, including its reputation and license.

The risk of exposure to terrorism financing varies across customers, countries, products, services, and over time. High-risk situations require stronger controls compared to lower-risk situations. To effectively manage and mitigate these risks, a risk-based approach is implemented. This approach prioritizes the allocation of resources to address the most significant risks.

In accordance with the relevant laws, AI Crypto Market's assessment of its exposure to TF adheres to a risk-based approach. AI Crypto Market has evaluated and will persist in assessing and quantifying TF risks by considering the risks associated with the following factors:

• its customer types
• the types of designated services it provides
• the methods by which it delivers designated services
• the foreign jurisdictions with which it deals
• the staff recruitment and retention

As per the Prevention of Money Laundering Act & The Bank Secrecy Act and the US Code, it is mandatory for a Digital asset service provider to establish and adhere to an AML & CTF Program hence AI Crypto Market's AML & CTF Program has been designed, as per the regulations. The AML & CTF Program is applicable to all Representatives of AI Crypto Market. The policies, processes and procedures:

• To implement the transaction and activity reporting requirements
• To implement customer due diligence requirements
• To implement the record keeping requirements
• To inform AI Crypto Market's officers and employees of the laws of USA about money laundering and financing of terrorism, of the policies, processes, procedures and systems adopted by the entity to deal with money laundering and financing of terrorism
• To train the entity's officers and employees to recognize and deal with money laundering and terrorism financing
• On the role and responsibility of AML and ATF Compliance officer
• On the establishment of an independent audit function which is able to test its AML & CTF processes, procedures and systems
• On the adoption of systems by AI Crypto Market to deal with money laundering and terrorism financing, on the staff screening, recruitment and retention program

The core aim of the AML & CTF Program is to recognize, alleviate, and oversee the risk that AI Crypto Market may encounter (whether intentionally or inadvertently) by enabling money laundering or terrorism financing through the provision of its designated services.

The primary purpose of the AML & CTF Program is to set out the applicable customer identification and verification procedures for customers of AI Crypto Market.

The KYC and CDD process is a mandate before the on-boarding of the customer. Additionally, the satisfaction of the following stated requirements is necessary to avail the services provided by AI Crypto Market:

• AI Crypto Market shall understand the purpose and intention of the customer for establishing a customer relationship with our concern. Thus AI Crypto Market will collect the relevant information and documents required.
• AI Crypto Market shall collect information on whether the customer willing to avail the services, is a Politically Exposed Person (PEP) or not; which not only includes the customer but it extends to the family members or a person known to be a close associate of the customer.
• The KYC and CDD procedure shall be extended to the beneficial owner (if any) of the customer, and to understand the customer's ownership and control structure from the information/documents collected by AI Crypto Market.
• If any person(s) acts on behalf of the customer, the KYC and CDD procedure as well as the right of representation shall be extended to such person.
• In the event of any doubts about the veracity or non-adequacy of the data provided by the customer as per the requirement of AI Crypto Market, additional documents or information shall be demanded from the customer to complete the KYC and CDD procedure as per the guidelines by the Financial Crime Enforcement Network (FinCEN).

If the customer is unable to comply with the KYC and CDD procedure as described, the establishment of the customer relationship (Customer On-Boarding) shall be refused/rejected.

For any existing customer, if they refuse to provide the documents/information for the periodic KYC and CDD procedure, it shall be deemed to be a fundamental breach of the contract and termination of the customer relationship. In addition, AI Crypto Market and the compliance team shall assess whether the circumstances constitute any material risk, and if found so a Suspicious Activity Reporting (SAR) shall be filed before the regulatory authorities which is the Financial Intelligence Unit (FIU-IND).

Please refer to the KYC and CDD Procedure for further information.

AI Crypto Market will also enforce thorough supervision procedures to authenticate the identity and previous record of prospective employees. Recognizing the potential risk due to staff turnover, AI Crypto Market has instituted protocols for training, monitoring, and applying transactional limits to new staff members (or existing staff members elevated to roles with heightened AML & CTF duties). Comprehensive training on the company's policies and procedures is mandatory at different points in employment.

Name screening is one of the major parts of the KYC and CDD procedure. The KYC verification agency shall perform name screening, watchlist checks. The name screening involves checking (with fuzzy matching capabilities) a customer's name against a commercial database for possible matches of PEPs, sanctions and adverse media checks. The commercial database is provided by Comply advantage which, together with KYC verification agency, collectively includes the following lists:

• International sanctions lists or the blacklist from the Financial Action Task Force (FATF), the United Nations (UN), the European Union (EU), the Office of Foreign Assets Control (OFAC), and Her Majesty's Treasury (HMT)
• PEP lists covering 200+ countries
• Criminal and law enforcement lists
• Interpol wanted lists
• Regulatory enforcement lists
• Adverse media

AI Crypto Market conducts the AML name screening process by following these below mentioned steps:

1. Acquiring the necessary information / data: AI Crypto Market collects the relevant information / data from the customers for the name screening purpose.
2. Organizing the data: AI Crypto Market uses a professional methodology to organize the information / data which are to be screened, for instance, making sure that the names are in correct format.
3. Conducting the screening: AI Crypto Market uses manual as well automated searching methods throughout the various lists such as Sanctions list or PEPs list.
4. Analyzing the result: AI Crypto Market reviews the matches that were found in the screening process and determines whether they are true matches or false positives.
5. Taking appropriate action: AI Crypto Market after analyzing the result, takes appropriate action, for instance, freezing the account or ending the business relationship with the customer, if a match is found.

A review of the CTF Program will be undertaken at least annually also in case of important changes of legal acts.

AI Crypto Market will set up an independent internal audit function (or opt for outsourcing to a third-party provider) to evaluate its CTF processes, procedures, and systems. This review and testing will be conducted either internally by a person independent from business units and the AI Crypto Market's CTF Compliance Officers, such as an internal auditor, or by an external service provider engaged specifically for this purpose.

The purposes of the review will be to:

• Assess the effectiveness of the AML & CTF Program having specific regard to the ML/TF risk faced by AI Crypto Market
• Assess whether the CTF Program complies with the AML & CTF Rules
• Assess whether the CTF Program has been effectively implemented
• Assess whether AI Crypto Market has complied with the CTF requirements

The information / data / documents provided by the customers which might be personal data or professional data for the KYC / CDD for the verification purposes before availing the services of AI Crypto Market are kept throughout the continuance of the business relationship with the customer and at least for five years after the end of the business relationship.

The transaction history or record made during the span of availing the services from AI Crypto Market are kept at least for five years after the completion of a transaction.

AI Crypto Market shall keep staff training records at least for three years after completing the training.

In any event, where any suspicion is recognized / identified by AI Crypto Market during transaction monitoring of any customer, the account shall be locked, and the transaction shall be suspended, and as soon as practicable, it shall be escalated with relevant account information and transaction details to the business relationship.

MLRO (Money Laundering Reporting Officer) for prompt review and investigation without undue delay. If warranted, the MLRO shall, within thirty calendar days from the date of identifying the activity, submit a suspicious transaction report (STR) to the appropriate supervisory authority which is the Financial Crime Enforcement Network (FinCEN).

It is prohibited by law from disclosing (tipping-off) to any person, any information which might prejudice an investigation. For instance if a customer is told that a report or related information is being filed with the regulatory authority (FinCEN), this would prejudice the investigation and lead to a violation of the law.

After submission of the STR to the appropriate regulatory authority (FinCEN), a precept shall be made by them, and after the precept is complied with, the customer will be informed that the regulatory authority has restricted the use of his/her account or that another restriction has been imposed.

It is the duty of AI Crypto Market to report immediately, in case of any suspicion / unusual activity of money laundering and terrorist financing to the appropriate regulatory authority (FinCEN), but not later than thirty calendar days from the date of identifying / recognizing such activity.