AML-KYC Policy

Overview

The Company adheres to and complies with "Know Your Customer" principles, which aim to prevent financial crime and money laundering through client identification and due diligence. The Company reserves the right, at any time, to ask for any KYC documentation it deems necessary to determine the identity and location of a user. We reserve the right to restrict the service, payment, or withdrawal until identity is sufficiently determined, or for any other reason in our sole discretion based on the legal framework.

Risk-Based Approach

We take a risk-based approach and perform strict due diligence checks and ongoing monitoring of all clients, customers, and transactions. As per the money laundering regulations, we utilize three stages of due diligence checks, depending on the risk, transaction, and customer type:

• SDD — Simplified Due Diligence is used in instances of extremely low-risk transactions that do not meet the required thresholds.
• CDD — Customer Due Diligence is the standard for due diligence checks, used in most cases for verification and identification.
• EDD — Enhanced Due Diligence is used for high-risk customers, large transactions or special cases.

When KYC is Required

Separately and in addition to the above, when a user makes an aggregate lifetime total of deposits exceeding €5,000, requests a withdrawal of any amount, or attempts to or completes a transaction that is deemed suspicious, then it is compulsory for them to complete the full KYC process. During this process, the user will have to input some basic details about themselves and then upload:

• A copy of Government Issued Photo ID (in some cases front and back depending on the ID document).
• A selfie of themselves holding the ID document.
• A bank statement or utility bill.

KYC Process Guidelines

Restricted Countries

Customers residing in or holding documents issued by the following jurisdictions are not eligible:

• Austria
• France and its territories
• Germany
• Netherlands and its territories
• Spain
• Union of Comoros
• United Kingdom
• USA and its territories
• All FATF Blacklisted countries
• Any other jurisdictions deemed prohibited by Anjouan Offshore Financial Authority

Process Notes

• When the KYC process is unsuccessful, the reason is documented and a support ticket is created in the system. The ticket number along with an explanation is communicated back to the user.
• Once all proper documents are in our possession, the account gets approved.