AML Policy

Version 6

Date: 01/02/2024 Next revision planned: 01/08/2024

Finandy Limited is a company, which provides its clients trade facilities within the platform of Binance crypto exchange and OKX crypto exchange. Finandy Limited manages the crypto assets on its clients accounts and receives commission.

Finandy Limited is registered as per legislation of Seychelles and has no branches anywhere.

Finandy Limited had designed this ANTI MONEY LAUNDERING and COMBATING FINANCING OF TERRORISM Policy (hereinafter - AML Policy) to prohibit and actively prevent the money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities or flow of illegal money or hiding money to avoid paying taxes. Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have derived from legitimate origins or constitute legitimate assets.

This policy provides detailed procedures and obligations to be followed to ensure compliance with issues related to KNOW YOUR CLIENT (KYC) Norms, ANTI MONEY LAUNDERING (AML), CLIENT DUE DILIGENCE (CDD) and COMBATING FINANCING OF TERRORISM (CFT).

I. KEY DEFINITIONS

Act - Anti-Money Laundering and Countering the Financing of Terrorism Act, 2020 (the Seychelles) with amendments

AMLO - Anti-money laundering officer - a person responsible for ongoing AML activities in Finandy Limited

Client's Account - means sub-account, which is open by Finandy Limited to the client as a part of Finandy Limited account with Binance crypto trade ecosystem for trade purposes.

FATF - Financial Action Task Force, the inter-governmental body which sets international standards that aim to prevent these illegal activities and the harm they cause to society.

FIU - Financial intelligence unit of Seychelles (https://www.seychellesfiu.sc/)

STR – Suspicious Transaction Report

II. KYC PROCEDURES

KYC is a matter of vital importance for Finandy Limited activities. Finandy Limited accepts clients - natural persons above 18 years old.

Finandy Limited does not accept:

• legal entities,

• funds,

• trusts,

• state bodies.

Information about a client to be collected include:

(a) Full name;

(b) Date of birth;

(c) Nationality;

(d) Identity document type and number; and

(e) Residential address.

Finandy Limited should obtain a valid travel document - passport.

As an exception Finandy Limited may accept:

• A relevant national identity card (issued by government) bearing the person’s photograph; or

• A valid national driving license (issued by government) bearing the person’s photograph.

The copies of the abovementioned documents are kept during the ongoing relations with the customer and 5 years after the relations with the customer are terminated.

To verify that the document really belongs to prospective client Finandy Limited may demand to make a selfie and submit it through web-site. The person should be without glasses/hat.

Politically exposed persons (PEP)

A politically exposed person (PEP) is defined by the FATF as an individual who is or has been entrusted with a prominent public function. Due to their position and influence, it is recognized that many PEPs are in positions that potentially can be abused for the purpose of committing money laundering (ML) offences and related predicate offences, including corruption and bribery, as well as conducting activity related to terrorist financing.

Finandy Limited does not accept PEPs as clients. If an existing client becomes PEP Finandy Limited terminates the relations with such client giving 30 days prior notice.

In case a person being PEP was accepted as a client, Finandy Limited has the right to terminate the relations immediately, close all the orders and return all the funds to the client.

As an exception, Finandy Limited may maintain relations with former PEP (if a person retired, stopped its political activity and so on).

FATF "Call for action" list

Finandy Limited does not establish or maintain business relations with citizens/residents of FATF "Call for action" list countries:

• Iran

• Democratic People's Republic of Korea (DPRK).

In case FATF revises its list, Finandy Limited acts accordingly.

As far as Binance does not accept clients from:

• Canada

• Netherlands

• United States

• Syria

• Unrecognized territories of the DPR and LPR

Finandy Limited does not accept clients from these jurisdictions either.

Finandy Limited informs the clients that if they are temporally on the territory of the abovementioned countries, they have no right to inflow/outflow the assets on their Accounts.

Finandy Limited divides the clients into groups depending on the level of risk:

• high-risk clients,

• standard risk clients.

High-risk clients are:

• those, who are citizens/residents of "jurisdictions with strategic deficiencies" and "high-risk third countries"

Finandy Limited relies upon FATF and European Commission in definition of the countries which has deficiencies in AML.

High-risk jurisdictions for which EDD apply include the countries from the lists of FATF "Jurisdictions with strategic deficiencies" and European Commission "High-risk third countries":

Jurisdictions with strategic deficiencies	High-risk third countries
Bulgaria Burkina Faso Cameroon Democratic Republic of Congo Croatia Haiti Jamaica Kenia Mali Mozambique Namibia Nigeria Philippines Senegal South Africa South Sudan Syria Tanzania Turkey Yemen Vietnam	Afghanistan Barbados Burkina Faso Cameroon Democratic Republic of Congo Hibraltar Haiti Jamaica Mali Mozambique Myanmar Nigeria Panama Philippines Senegal South Africa South Sudan Syria Tanzania Trinidad and Tobago Uganda UAE Vanuatu Vietnam Yemen

As far as the level of anti-money laundering is not sufficient in these countries MLRO, when considers appropriate, may demand proof of origin of funds (salary slips, transfer of dividends, sale of assets and etc.).

Access based on KYC

Finandy Limited grants access to its services on condition of KYC procedure passed by the client.

III. CUSTOMER DUE DILLIGENCE

Customer due diligence (CDD) is intended to enable the Company to form a reasonable belief that it knows the true identity of each customer with a high degree of confidence.

Types of CDD

Standard CDD

A standard level of CDD, generally to be applied to all customers to whom specified services are provided, which are met in person.

As far as most part of the clients establishes relations without face-to-face meeting with management team of Finandy Limited, Enhanced CDD should apply.

Enhanced CDD

An increased level of CDD for those clients that are reasonably determined by to be of higher risk due to the country of residence.

Ongoing DD

MLRO officer carries out ongoing due diligence as per the following schedule:

Type of client	Regularity	Notes
Standard risk clients	Once a year	MLRO might demand to present the confirmation of the place of residence checks
High risk clients	Once every 6 months	MLRO checks if the clients are on sanction lists
Clients - residents from Russia	Once every 6 months	MLRO checks if the clients are on sanction lists

All the clients are checked whether they became PEPs on annual basis.

Finandy Limited undertakes reviews of existing records of customers under circumstances of certain triggering events, including:

(a) when a significant transaction (i.e. in terms of monetary value or where the transaction is unusual or not in line with the the customer previous activities) is to take place;

(b) when Finandy Limited is aware that it lacks sufficient information about the customer concerned.

IV. STAFF TRAINING

The training of staff is a significant factor for defeating money laundering or terrorist financing and you should be able to prove that all staff are aware of the law and their personal obligations.

Records of training provided/received should include the recording of attendance lists at training sessions, staff declaration of awareness of the law/regulations, filing of training manuals, records of training for new staff to show they are aware of the practice’s internal policy and the ML laws or regulations.

It is common for professionals to give training on AML/CTF to staff without any formal record being taken (eg. ‘On-the-job training’).

All the staff may be trained on-the-job, except for MLRO.

Main directions for staff training:

(a) Finandy Limited statutory obligations;

(b) the possible consequences of breaches of these obligations;

(c) Finandy Limited policies and procedures relating to AML/CTF, including suspicious transaction identification and reporting.

At a minimum staff is trained at least once every two years on money laundering. However, there are a number of factors that leads to additional training.

• When staff join the business

• When staff move to a new job

• When staff change roles in an organisation

• When a change happens in the legislation

• When a change in the level of risk occurs

All new staff (irrespective of seniority) must execute the following:

a. Read the AML Policy and the Act

b. Read Binance Terms and Conditions

Then MRLO asks question or gives tests to an employee.

MLRO must take regular training. The place where training is taken place does not matter. MLRO must also be trained concerning crypto currency issues: legal nature, regulation, licensing.

In any case the Finandy Limited keeps records about the training provided for at least 5 years.

V. SANCTIONS POLICY

Finandy Limited respects sanctions imposed by European Union, United nations organization and OFAC (United States Department of the Treasury’s Office of Foreign Assets Control.

Finandy Limited is committed to complying with all sanctions applicable to business activities.

Finandy Limited does not participate in transactions or engage in conduct designed or intended to evade or facilitate a breach of applicable sanctions.

Finandy Limited does not conduct business in, or involving any, embargoed territory or sanctions targets.

Finandy Limited does not conduct business that would violate any applicable trade controls or anti-boycott laws.

Finandy Limited only allows deviations from these general requirements in exceptional circumstances with prior approval from senior management and, under all circumstances, these must be compliant with applicable laws.

To manage sanctions risk exposure and ensure compliance, Finandy Limited implement controls and processes including screening and due diligence on counterparties.

Finandy Limited uses a risk-based approach to determine whether they are a sanctions target or otherwise attract sanctions risk.

Finandy Limited requires employees to be alert to sanctions risk and to report any sanctions issues identified to compliance.

Finandy Limited does not accept individuals from sanction lists of European Union and United Nations. MLRO as said above revises sanctions list and current clients if there are any changes concerning their being in sanction lists.

MLRO revises clients - Russia and Belorussia every 6 months. In case they appear in sanctions lists, MLRO reports to the management and Finandy Limited ceases business relations and returns the funds to the clients.

VI. MONEY LAUNDERING REPORTING OFFICER

Money Laundering Reporting Officer (MLRO) – provides oversight for the Company’s anti-money laundering systems, and acts as a focal point for related inquiries. The role involves a significant amount of responsibility: MLROs must have access to the firm’s financial records in order to provide oversight and must make strategic decisions about activities relating to money-laundering and financial crime.

MLRO is an extremely important position within a business, so it is vital that senior managers understand and think carefully about the role.

The key demands to MLRO:

MLRO should possess:

• Degree of a reliable university or similar education,

• Profound knowledge in AML processes in the world,

• Good command of AML legislation of Seychelles,

• Good command of FATF recommendations, policies and related guidelines,

• Additional training in AML.

MLROs assesses money-laundering risk. This skill requires not only an understanding of criminal methodologies but an understanding of the behavior and business practices of customers and clients, who may themselves be exposed to risk.

It goes without saying that dedication, honesty and integrity are fundamental traits for a Money Laundering Reporting Officer.

The key obligations of MLRO:

• Review all internal reports of suspicious transactions and exception reports and, in the light of all available information, determine whether or not it is necessary to file a suspicious transaction report (“STR”)with the Financial Intelligence Unit of Seychelles.

• Maintain all records relating to such internal reviews.

• Act as the main point of contact with the Financial Intelligence Unit, law enforcement agencies, and any other competent authorities in relation to ML/TF prevention and detection, investigation or compliance.

• Monitor the effectiveness of the policies and processes and the risks in order to make changes where applicable.

• Consider reports of money laundering sent to FIU and decide, whether the grounds were sufficient.

Besides, MLRO decides:

• Whether to implement changes to the Company's internal documents,

• How to act in doubtful situations,

• Whether the stuff or particular person needs special or additional training,

• To draft training programme.

MLRO:

(a) has senior level of authority in Finandy Limited;

(b) is provided with regular contact with, and when required, has direct access to senior management to ensure that senior management is able to satisfy itself that the statutory obligations are being met and that the business is taking sufficiently robust measures to protect itself against ML/TF risks;

(c) is capable of accessing, on a timely basis, all available information, both from internal sources and external sources; and

(d) equipped with sufficient resources,

(e) must be given access to good legal advice about this aspect of their role or to be a lawyer himself/herself.

VII. REPORTING SUSPICIOUS TRANSACTIONS

Once the Finandy Limited identifies or suspects that a transaction is related to ML/TF activity,

The “SAFE” approach

An effective systemic approach to identify suspicious transactions may safeguard the Finandy Limited from the risk of being involved with ML/TF. The Company adopts, where applicable, the “SAFE” approach promoted by FIU.

Four steps are involved in the SAFE approach:

(a) Screen the account for suspicious indicators;

(b) Ask the customers appropriate questions;

(c) Find out the customer’s records; and

(d) Evaluate all the above information.

When Finandy Limited knows or suspects that certain property represents the proceeds of crime or terrorist property, a disclosure must be made to the FIU as soon as it is reasonable to do so.

STRs shall be made to the FIU before the Finandy Limited deals with a suspicious transaction or activity (whether the intended transaction ultimately takes place or not) for its customer, or, where the relevant knowledge or suspicion arises only after the transaction or activity has been completed, be made to the FIU as soon as reasonably practicable.

Internal reporting

Finandy Limited should have measures in place to check, on an ongoing basis, that it has proper policies and procedures to test and ensure compliance with legal and regulatory requirements. The type and extent of the measures to be taken in this respect should be appropriate having regard to the risk of ML/TF and the size of their respective business.

The MLRO should act as a central reference point for reporting suspicious transactions. Finandy Limited should ensure that the MLRO has sufficient status within the organization, and has adequate resources, to enable the MLRO to perform his/her functions.

A key responsibility of the MLRO is to diligently consider all vital information and report the suspicious transaction or activity or suspicious attempted transaction or activity to the FIU in accordance with statutory requirements.

Finandy Limited ensures that:

(a) all staff are made aware of the identity of the MLRO and the procedures to follow when making an internal disclosure report; and

(b) all disclosure reports must reach the MLRO without undue delay.

All the staff should report to MLRO about any suspicious activity, and MLRO should inform management team.

All suspicious activities reported to the MLRO are documented. The report must include the full details of the customer and a full statement on the information giving rise to the suspicion. In urgent cases, suspicious activities may be reported verbally, e.g. over the telephone, to be followed by documentation.

The reporting of a suspicion in respect of a transaction or event does not mean that further suspicious transactions or events in respect of the same customer need not be reported. Further suspicious transactions or events, whether of the same nature or different to the previous suspicion, must also be reported to the MLRO who should make further reports to the FIU as appropriate.

When evaluating an internal report of suspicious transaction, the MLRO must take reasonable steps to consider all relevant information, including CDD and ongoing monitoring information available within the organization concerning the entities to which the report relates.

Steps to be taken by the MLRO include:

(a) a review of other transaction patterns and volumes through connected accounts;

(b) reference to any previous patterns of instructions, the length of the business relationship and CDD and ongoing monitoring information and documentation; and

(c) appropriate questioning of the customer using the systematic approach to identifying suspicious transactions as recommended by the FIU.

As part of the review, other connected business relationships may need to be examined. Regarding the need to search for information concerning connected business relationships, a balance should be struck between making a timely disclosure to the JFIU as required by law and any delays in making the disclosure that might arise from searching more relevant information. The evaluation process and the conclusion drawn should be documented.

If after completing the evaluation a MLRO decides that there are grounds for knowledge or suspicion of transactions related to money laundering/terrorist financing (ML/TF) activity, he/she should file a STR to the FIU as soon as reasonable together with the information or matters on which that knowledge or suspicion is based.

The Company must establish and maintain a record of all ML/TF reports made to the MLRO. The record should include details of the date the report was made, the staff members subsequently handling the report, the results of the evaluation, whether the report eventually resulted in a STR filed with the FIU, and information to allow the documentation relevant to the report to be located.

The Company maintains a record of all STRs made to the FIU. The record must include details of the date of the disclosure, the person who made the disclosure, and information to allow the papers relevant to the STR to be located. This register may be combined with the register of internal reports, if considered appropriate.

VIII. RECORD KEEPING

The Company maintains all relevant records of customers, transactions, etc. that are necessary and sufficient to meet the record-keeping requirements under the Act and other relevant regulatory requirements.

All the records concerning each customer and each transaction are kept during the relation with a customer is in process and 5 years after the relations are terminated.

Finandy Limited keeps the copies of the documents, and a record of the data and information obtained in the course of identifying and verifying the identity of the customer.

Concerning the transactions, the Company keeps all the information concerning inflows and outflows of the assets to the client's account, including:

• the nature and date of the transaction;

• the type and amount of currency/cryptocurrency involved;

• the origin of the funds (if known);

• the type and identifying number of any account involved in the transaction (where applicable).

If the record consists of a document, the copy of the document is kept in the database of a computer in any format. The same concerns any information received by the Company in the process of identification.

Format of record-keeping:

• Original documents,

• Photocopies or scans of original documents

• Computerized or electronic form records

• Electronic files or hard copies of the results of electronic/subscription services checks carried out.

Format of computer files:

• PDF - for scanned copies (BMP, JPEG possible);

• WORD/EXCEL - for information.

Where the documents are kept:

Originals - where the management body resides;

Computerized documents/records/scanned copies - where the MLRO considers appropriate.

Creation of a reserved copy of computerized documents is to be done every 3 months.

The MLRO maintains the access to the documents to the staff of the Company, but takes measures to prevent unauthorized access to the data.

IX. MISCHELLANEOUS

The current AML policy should be revised:

every 6 months or earlier in case of material changes of legislation or business.