Anti-money laundering (AML) Policy

1. GENERAL PROVISIONS

1.1. These AML Policy, or rules of procedure for prevention of money laundering and terrorist financing, and compliance with international sanctions (hereinafter Rules), has been developed by CHOICE LOAN LIMITED in order to prevent entering into deals involving suspected Money Laundering and Terrorist Financing and to ensure identification and reporting of such activities. The policy aims to create a standardized approach to preventing illegal transactions and to enhance organizational transparency and accountability. Any questions related to this policy should be addressed to the Compliance Department or to designated representatives within the organization.

1.2. The obligation to observe the Rules rests with all members of the Management Board, employees of the Company, including both temporary and full-time staff, as well as agents of the Company who initiate or establish Business Relationships (as defined in section 2.6) (hereinafter collectively referred to as Representatives). Every Representative is required to review and confirm their awareness of these Rules with a signature upon onboarding, which also mandates periodic reviews to ensure continuous compliance.

1.3. The Rules are based on the relevant provisions of the Money Laundering and Terrorist Financing Prevention Act (hereinafter the Act) and the International Sanctions Act (hereinafter ISA), integrating best practices as per these regulatory requirements.

2. DEFINITIONS

2.1. Money Laundering — activities undertaken to manage, handle, or process property derived from criminal activity or to mask the illicit origins of assets. This includes concealing or disguising the true nature, source, or ownership of illicit property, transferring or converting such property, or assisting others to evade legal consequences.

2.2. Terrorist Financing — any act of financial support for terrorism as outlined in § 2373 of the Penal Code of Great Britain, targeting resources that may be used in terrorist operations, directly or indirectly.

2.3. International Sanctions — non-military measures enacted by international entities, including the European Union, the United Nations, and the government of Great Britain, aimed at preventing threats to peace, security, and human rights.

2.4. Compliance Officer (CO) — a representative appointed by the Management Board to oversee adherence to the AML policy, act as the primary contact for the Financial Intelligence Unit (FIU), and ensure effective application of the Rules.

2.5. FIU — Financial Intelligence Unit of the Police and Border Guard Board of Great Britain, responsible for monitoring and responding to suspicious activities within financial channels.

2.6. Business Relationship — any formal economic or professional relationship established between the Company and its Client.

2.7. Client — any individual or legal entity that engages in financial transactions or otherwise utilizes the services provided by the Company.

2.8. Beneficial Owner — the natural person who ultimately controls a transaction or legal entity, defined by ownership of 25% or more of shares, senior managerial control, or being the designated beneficiary in a trust, partnership, or similar structure.

3. AML COMPLIANCE OFFICER

3.1. The Company has designated an AML Compliance Officer (CO) who bears full responsibility for the execution and enforcement of these Rules. The CO reports to the Management Board regarding any significant breaches of the internal AML policy, relevant legislation, and standards of good practice.

3.2. The AML Compliance Officer's key responsibilities include:

• - Verifying the identity of the Client and its representatives.
• - Gathering information and documentation to confirm the legal origin of funds.
• - Requiring additional information regarding Beneficial Owners of legal entities.
• - Re-identifying Clients if doubts arise concerning previously submitted information.
• - Initiating a security deposit requirement: when a Client seeks to add a new payment method or cryptocurrency wallet, they must first deposit an amount ranging from 3% to 25% of their total account balance, depending on the payment system, as a precautionary measure.
• - Ensuring strict use of personal accounts only: Clients are prohibited from using third-party payment cards, cryptocurrency exchanges, or wallets to which they do not have direct access. Deposits and withdrawals are permitted exclusively through the Client’s own verified cards, wallets, and exchanges.

3.3. The CO is also tasked with:

• - Monitoring compliance with these Rules throughout the organization.
• - Updating data regarding countries and economic activities based on risk levels.
• - Providing training sessions and updates to Representatives on AML compliance.
• - Reporting to the Management Board at least annually, or more often if needed, regarding suspected cases of Money Laundering or Terrorist Financing.

4. MONEY LAUNDERING MONITORING

4.1. The Company maintains the right to conduct ongoing checks of its Clients, which may involve regularly reviewing and updating relevant data. This monitoring program evaluates risk profiles and behaviors to ensure that any discrepancies are promptly addressed.

4.2. The AML compliance framework requires the CO to conduct periodic assessments of the effectiveness of internal controls and processes to counter financial crime. Findings are reported to the Management Board.

4.3. These measures reinforce CHOICE LOAN LIMITED’s commitment to detecting and preventing money laundering and terrorist financing.