AML/KYC Policy

1. Anti-Money Laundering Law

The Company upholds its integrity of observing regulations under the Anti-Money Laundering (“AML”) compliance. The intention of this policy is to filter illegal activities, including securities fraud, terrorist financing, and other unlawful acts in connection with concealing the origins of illegally obtained money.

In compliance with the relevant financial regulations, the Company conducts authentication and verification procedures for the Client’s identification. The Client must provide the necessary documents to complete the procedure in compliance with this policy. The Company keeps record of the Client’s documents and transactions for security purposes.

The Clients, Fundiza Ltd., and the Company’s workforce shall hereby act in accordance with the Anti-Money Laundering Policy, where necessary documents must be presented accordingly for verification.

The Company records all transactions performed through the Website and through the corresponding banks and financial institutions for security purposes. Furthermore, the AML Compliance Committee executes Suspicious Activity Reports (or “SARs”) and other mandatory disclosure in writing to the relevant legal administrations.

The Company and its workforce commit to the prevention of money laundering and other unlawful activities. The business division of the Company undergoes risk-based methods judiciously estimated to filter and identify the aforementioned reporting and writing under the International Anti-Money Laundering Law.

2. Judicial

The Company is unwavering to its public responsibility to avert illegal misconducts. The Company and its workforce strictly observe the verification practices and is vigilant to further prevent and control risks that can affect the Company’s operations.

The Company is always aware about any national and global occurrence of initiatives to further prevent terrorism funding, money laundering, tax evasion, and other illegal financial activities. The Company justifies the protection of its managerial operations, personal records of employees and the Clients, and all forms of documents confidential in nature. Any form of threat in relation to illegal financial activities will deal with legal proceedings.

3. Verification of Identity

Identity verification includes, but is not limited to, the provision of the Client’s complete name and address, date of birth, passport number and country of issuance, and other personal information that the Company may request for.

The Client ensures to provide true and accurate information which will be a recorded data as part of his/her identification. The Company reserves the right to reject, cancel, or suspend any transaction if any form of information discrepancy occurs. Transactions with third parties on behalf of the Client must have a Power of Attorney (“POA”) subject to the approval of the Company. If the third-party transaction was not approved, the Company reserves the right to consider the transaction invalid without prior notice.

4. Know Your Customer Policy

In compliance with the AML Policy, the Company has set the Know Your Customer (“KYC”) Policy in due diligence procedures for customer identification. This policy also intends to distinguish the intention of grand larceny, identity theft, financial fraud, and terrorist funding.

The Client must provide certain information and documentation to the Company to verify his/her identity, nature of business, and intended purpose of transactions. The Company requires the Clients to submit the needed documents as soon as possible to avoid delays when making transactions.

In certain conditions, the Company reserves the right to demand additional documentations from the Client before allowing him/her to perform further actions such as depositing, withdrawing, or trading.

The following factors are considered in assessing the risks of violating the AML Policy:

• - Whether the Client is an individual, an intermediary, a financial or non-financial institution, or a regulated person or entity
• - If the Client is already registered and is managing multiple accounts more than the Company allows
• - Means of how the Client was referred
• - If the Client’s business or trading account has a greater likelihood of being involved in unlawful activities
• - If the Client’s residence is from a jurisdiction with bank secrecy laws

5. Verification Procedures

The Company will obtain the necessary information to verify the Client’s identity. The Client must thereby ensure that the information and other personal details he/she provides the Company are true, accurate, and complete.

To comply accordingly with the procedures for identity verification, the Client should be able to provide the following, without limitation:

- A copy of a valid ID for proof of identity showing the Client’s full name and signature

• Government-issued ID
• National or foreign passport showing the 2 relevant pages
• Driver’s license showing the front and back side

- Any copy of a document that verifies your proof of residence not older than 3 months, which should be identical to the Client’s name and address as registered with the Company

• Bank statement
• Utility bill
• Certification of residence
• Government-issued lease agreement

- Copies of the card used to deposit

• Front and back must display full name and the last 4 digits (first 12 digits must be covered)
• If card does not have a displayed name, front and back must show the first 6 and last 4 digits only.
• Back copy must cover the CVV, while the signature and card numbers must be shown accordingly

The Client can scan or take a clear photo of the documents with legible texts, while all corners and sides are visible. The Client must provide the documents only in the format of .jpeg, .png, or PDF without password protection.

All documents can be submitted through email (services@fundiza.com), or through uploading on the Website. Verification process will only be conducted after the Client’s initial deposit of 250 USD. To verify that each transaction is made by the Client, the Company will send a Declaration of Deposit document to the Client’s registered email every time he/she conducts a deposit transaction. The Client agrees that this document must be signed immediately upon receipt.

The Company upholds the security of documentation at highest priority and would treat all documents received with utmost respect and confidentiality. All records that the Company acquires are protected with prominent encryption in every step of the verification process.