【Contract List】- Anti Money Laundering / Know Your Customer (AML/KYC) Policy

DIGIFINEX LIMITED & DIGIFINEX CANADA LIMITED & DigiFinex Hong Kong Limited: AML/KYC POLICY

This document was last updated on July 7, 2020.

The Company protects itself from involvement in money laundering or suspicious activity by the following:

Establishing detailed AML policies and procedures.
Performing know your customer ("KYC") procedures on all users including individuals and corporate users.
Designating a Compliance Officer with full responsibility to follow AML policies strictly.
Conducting an AML audit anually .

Policies and Procedures

The Policy will be approved by the Company¡'s Board. All policies and procedures will be reviewed and updated or revised as needed, but no less often than annually.

AML Compliance Officer

The Company has a Compliance Officer to be responsible for the management, coordination and monitoring of compliance with this policy and all applicable AML laws and regulations. The Compliance Officer will have a working knowledge of all AML laws and be qualified by knowledge, experience and training. The Compliance Officer will be responsible for all record keeping requirements and provide reports on the effectiveness of the AML program to the Company¡'s Board.

CUSTOMER IDENTIFICATION

It is the Company's policy to ensure that it has reasonably identified each customer who uses the Company's virtual currency trading platform. Users may be identified using a variety of methods.

Account Opening Procedures.

The Company require users to provide proof of identification; and will not permit any trades to be made by un-verified users.

Proof of Identification:

Individual Users

Name
Date and place of birth
Email Address
Contact Phone number
Residence address and mailing address if different (PO Box address will not be acceptable).
Copy of valid photo identification (e.g., Passport number, Government Issued Identification Number, Social security number, Employee identification number or Individual taxpayer identification number)
Proof of address (e.g., Utility Bill, Telephone Bill, Bank Statement, Credit card statement etc.)

Businesses Users

Business name
Name of businesses representative for the account
The proof of address of the customer¡'s principal place of business and, if different, the customer¡'s mailing address. If the customer has a local address different from its principal place of business, the local address.
Copy of valid photo identification for the directors (e.g., Passport number, Government Issued Identification Number, Social security number, Employee identification number or Individual taxpayer identification number)
Company M & A and profile of the company.

Verification

Users will have option to load the document electornically from his account. Documents used in opening an account relationship will be verified prior to establishing the account. Verification of identity will require multi-factor authentication to ensure a meaningful user identity confirmation process based on account size or other factors.

The following are examples of verification methods the Company may use:

Obtaining proof of address, such as a copy of a utility bill, Telephone bill or bank statement from the account holder.
Having a telephone call to the number given in account opening form.
Obtaining a financial statement for a business account.
Comparing the identifying information with information available from a trusted third party source.
Photo ID of the users or the Directors for the company account.
Obtaining a notarized copy of an individual¡'s birth certificate or a business¡' certificate of incorporation sealed with an apostille for valid identification .
When the type of account increases the risk that the Company will not be able to verify the true identity of the customer through documents is confirmed the account will be closed.

SUSPICIOUS TRANSACTION AND ACTIVITY REPORTS

The Company will diligently monitor transactions for suspicious activity. Transactions that are unusual will be carefully reviewed to determine if it appears that they make no apparent sense or appear to be for an unlawful purpose. When such suspicious activity is detected, the Compliance Officer will determine whether a filing with any law enforcement authority is necessary.

Suspicious activity can include more than just suspected money laundering attempts. Activity may be suspicious, and the Company may wish to make a filing with a law enforcement authority, even if no money is lost as a result of the transaction.

The Compliance Officer will initially make the decision of whether a transaction is potentially suspicious. Once the Compliance Officer has finished his review of the transaction details, he or she will consult with the Company¡'s senior management to make the decision as to whether the transaction meets the definition of suspicious transaction or activity and whether any filings with law enforcement authorities should be filed.

REPORTING REQUIREMENTS

Reasonable procedures for maintaining records of the information used to verify a person¡'s name; address and other identifying information are required under this Policy. The following are required steps in the record keeping process:

The Company will maintain a record of identifying information provided by the customer.
The Company will ecord the methods and result of any additional measures undertaken to verify the identity of the customer.
All transaction and identification records will be maintained for a minimum period of five years.

AML AUDIT

The Compliance Officer is responsible for directing the annual AML audit of the Company¡'s operations. The Compliance Officer will provide the audit report and all corrective action plans to the Company¡'s senior management for review.

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