KYC/AML Policy

ANTI-MONEY LAUNDERING (AML) & KYC POLICY

Emiverse SVG LLC

1. INTRODUCTION

This Anti-Money Laundering and Know Your Customer Policy (the “Policy”) establishes the framework adopted by Emiverse SVG LLC (the “Company”), a company incorporated in Saint Vincent and the Grenadines, to prevent, detect, and mitigate risks associated with money laundering, terrorist financing, fraud, and other forms of financial crime.

The Company operates the platform available at emirex.com and provides digital asset and payment-related services under the “Emirex” brand.

The Company is committed to conducting its business in accordance with applicable international AML/CFT standards, including generally accepted regulatory principles, a risk-based approach to compliance, and the implementation of effective internal governance, risk management, and control mechanisms.

This Policy defines the principles, procedures, and controls implemented by the Company to ensure compliance with applicable legal and regulatory requirements, as well as to safeguard the integrity of its operations and, more broadly, the financial system.

The provisions of this Policy apply to all users of the Company’s Services, as well as to the Company’s employees, contractors, and partners involved in its operations. All such persons are required to comply with the requirements set out herein, as applicable to their role and involvement.

The Company maintains an ongoing commitment to the review and enhancement of this Policy and its underlying procedures, in order to reflect changes in its business model, risk profile, and the evolving regulatory environment.

2. BUSINESS MODEL OVERVIEW

The Company operates as a provider of digital asset and payment-related services, offering infrastructure and transactional solutions in connection with the conversion and transfer of digital assets and fiat currencies.

The Company’s activities may include, without limitation, crypto-to-fiat and fiat-to-crypto conversions, over-the-counter (OTC) transactions, merchant payment processing solutions, and related settlement infrastructure.

The Company operates within a controlled and compliance-oriented framework and does not engage in activities that fall outside its defined operational model. In particular, the Company does not provide custodial wallet services unless explicitly stated and agreed within a specific product offering, does not support or facilitate anonymous transactions, and does not provide services to prohibited industries or restricted users.

All transactions facilitated by the Company are conducted through traceable and compliant channels and are subject to applicable AML/CFT requirements, internal risk controls, and monitoring procedures.

The Company may rely on regulated or compliant third-party service providers for certain aspects of transaction execution, settlement, or processing. In such cases, the Company ensures that such counterparties operate in accordance with applicable regulatory standards.

This business model forms the basis for the Company’s risk assessment and the implementation of its AML/CFT framework.

3. AML COMPLIANCE FRAMEWORK

The Company applies a risk-based approach (RBA) to AML compliance.

Core elements:

• Customer Due Diligence (CDD)
• Enhanced Due Diligence (EDD)
• Transaction Monitoring
• Sanctions Screening
• Risk Assessment
• Internal Controls

4. RISK-BASED APPROACH

Risk is assessed across the following dimensions:

Risk Category	Description
Customer Risk	Profile, behavior, ownership structure
Geographic Risk	Country exposure and jurisdiction
Product Risk	Type of services used
Product Risk	Volume, frequency, patterns

The Company applies:

• Simplified Due Diligence (SDD) for low-risk cases
• Enhanced Due Diligence (EDD) for high-risk cases

5. CUSTOMER DUE DILIGENCE (CDD)

The Company performs Customer Due Diligence (“CDD”) measures in order to identify and verify the identity of all users prior to establishing a business relationship, as well as on an ongoing basis where required.

CDD procedures are designed to ensure that the Company has a clear understanding of the user’s identity, ownership structure, and intended use of the Services, in line with applicable AML/CFT requirements and the Company’s risk-based approach.

For individual users, the Company collects and verifies personal identification information, which may include, without limitation, full name, date of birth, government-issued identification, and proof of residential address. Verification is conducted using reliable and independent sources.

For legal entities, the Company performs verification of corporate information, including incorporation documents, identification of ultimate beneficial owners (UBOs) holding, directly or indirectly, 25% or more of the ownership or control, as well as verification of directors and authorized representatives acting on behalf of the entity.

The Company may request additional information or documentation where necessary to clarify the ownership structure, business activities, or intended use of the Services.

CDD measures are applied on a risk-sensitive basis and may be supplemented by Enhanced Due Diligence (EDD) where higher risks are identified.

The Company reserves the right to refuse onboarding, restrict access to Services, or terminate the business relationship where sufficient identification or verification cannot be obtained, or where the risk profile of the user is deemed unacceptable.

6. ENHANCED DUE DILIGENCE (EDD)

The Company applies Enhanced Due Diligence (“EDD”) measures in situations where a higher level of risk is identified in connection with a user, transaction, or business relationship.

EDD is conducted as part of the Company’s risk-based approach and may be triggered by various factors, including but not limited to high transaction volumes, unusual or inconsistent behavioral patterns, involvement of high-risk or sanctioned jurisdictions, politically exposed person (PEP) status, or any other indicators suggesting elevated financial crime risk.

Where EDD is required, the Company undertakes additional verification and assessment measures to obtain a more comprehensive understanding of the user’s identity, financial background, and intended use of the Services.

Such measures may include, without limitation, obtaining and verifying information relating to the source of funds (SoF) and source of wealth (SoW), conducting detailed analysis of the user’s business activities, and requesting supporting documentation to substantiate the legitimacy of transactions.

The Company may also apply increased monitoring, impose transaction limits, or require additional approvals prior to processing transactions involving higher-risk users.

The Company reserves the right to decline, suspend, or terminate any business relationship or transaction where sufficient information cannot be obtained, or where the identified risks cannot be adequately mitigated in accordance with the Company’s internal policies and applicable regulatory requirements.

7. SANCTIONS & PEP SCREENING

The Company conducts sanctions and politically exposed persons (PEP) screening as part of its AML/CFT compliance framework in order to identify and mitigate risks associated with financial crime, including money laundering, terrorist financing, and sanctions evasion.

All users are subject to screening against applicable international sanctions lists, including but not limited to those maintained by the European Union, the United Nations, and other relevant authorities, as well as databases of politically exposed persons and adverse media sources where appropriate.

Screening is performed at onboarding and on an ongoing basis throughout the business relationship. The Company may also conduct additional screening in connection with specific transactions or changes in user activity.

Where a potential match or risk indicator is identified, the matter is subject to further review in accordance with the Company’s internal procedures. The Company may apply appropriate measures, including escalation to the Compliance Function, temporary restriction or suspension of access to Services, and the application of enhanced due diligence measures.

The Company reserves the right to refuse onboarding, suspend services, or terminate the business relationship where sanctions exposure or unacceptable risk is identified.

Where required under applicable laws and regulations, the Company will comply with its obligations to report or act upon sanctions-related findings in accordance with applicable legal requirements.

8. TRANSACTION MONITORING

The Company applies ongoing transaction monitoring procedures as part of its AML/CFT framework in order to identify, assess, and mitigate risks associated with money laundering, terrorist financing, fraud, and other illicit activities.

Monitoring is conducted on a continuous basis and is designed to detect unusual or suspicious patterns of behavior by analyzing transactional data in the context of the user’s known profile, business activity, and expected usage of the Services.

The Company’s monitoring framework includes, but is not limited to, the assessment of transaction size, frequency and velocity, analysis of counterparties involved in transactions, and evaluation of transactional flows across different jurisdictions. Where applicable, the Company may also utilize blockchain analytics tools and third-party risk assessment solutions to enhance visibility into digital asset transactions.

The monitoring process is risk-based and may involve automated systems, manual review, or a combination of both. Transactions or patterns identified as potentially unusual or inconsistent with the user’s profile are subject to further analysis and may trigger additional compliance measures.

Where necessary, the Company may request additional information or documentation, apply enhanced due diligence, restrict or suspend transactions, or escalate the matter to the Compliance Function for further investigation.

The Company acknowledges that, depending on its operational model and reliance on third-party service providers, visibility into certain transaction elements may be limited. In such cases, the Company relies on available information and, where appropriate, on the compliance controls of regulated counterparties involved in the execution or settlement of transactions.

9. SUSPICIOUS ACTIVITY

The Company maintains procedures for the identification, assessment, and handling of suspicious activities in connection with the use of its Services.

Suspicious activity may include, without limitation, transactions or patterns of behavior that are inconsistent with the user’s known profile, lack a clear economic or lawful purpose, involve unusual structuring or sequencing of transactions, include the use of third parties without transparent justification, or demonstrate rapid movement of funds without a reasonable explanation.

The Company applies a risk-based approach in assessing such activities, taking into account factors such as transaction size, frequency, counterparties involved, geographic exposure, and overall behavioral patterns.

Where potential suspicious activity is identified, the Company may take appropriate measures, including requesting additional information or documentation from the user, conducting enhanced due diligence, temporarily restricting or suspending access to Services, and escalating the matter to the Compliance Function for further review.

The Company reserves the right to decline, suspend, or terminate any transaction or business relationship where sufficient clarity or comfort cannot be obtained, or where the activity is deemed to present an unacceptable level of risk.

Where required under applicable laws and regulations, the Company may report suspicious activity to competent authorities in accordance with its legal obligations.

10. REPORTING

The Company maintains comprehensive internal reporting procedures designed to identify, escalate, and address any potential compliance risks, including but not limited to suspicious activities, compliance alerts, and risk-related incidents arising in the course of its operations.

All relevant events, transactions, or behaviors that may indicate potential money laundering, terrorist financing, fraud, or other illicit activities are subject to internal review and documentation. Such matters are promptly escalated in accordance with the Company’s internal escalation protocols.

Reports are handled by the Company’s Compliance Function, which is responsible for assessing the nature and severity of the reported issue, determining appropriate actions, and ensuring that all reporting obligations are fulfilled in accordance with applicable laws, regulations, and internal policies.

Where required, the Company may take further actions, including requesting additional information from users, restricting access to services, or preparing reports for submission to competent authorities, in line with applicable legal and regulatory requirements.

11. RECORD KEEPING

The Company maintains comprehensive records related to its AML/KYC obligations, including but not limited to customer identification data, verification documents, transaction records, and internal compliance reports. Such records are retained in order to ensure compliance with applicable legal and regulatory requirements, as well as to support internal risk management, audit, and investigative processes.

All records are securely stored and are accessible only to authorized personnel on a need-to-know basis. The Company ensures that record-keeping practices are aligned with applicable data protection standards and internal security policies.

The Company retains such records for a minimum period of five (5) years from the date of termination of the business relationship with the user or from the completion of a transaction, unless a longer retention period is required or permitted under applicable laws or regulatory obligations.

12. RISK TABLES (HEAVY PART)

12.1 BUSINESS RISK

Industry	Risk Level	Notes
Retail	Low	Standard payments
Crypto OTC	Medium	Requires monitoring
High-value goods	Medium-High	Potential ML exposure

12.2 PAYMENT RISK

Method	Risk	Notes
Bank Transfer	Low	Traceable
Card Payments	Medium	Chargeback risk
Crypto Transfers	Medium	Requires blockchain monitoring

12.3 FRAUD RISK

Scenario	Risk	Mitigation
Stolen funds	Medium	Monitoring + KYC
Chargebacks	Medium	Transaction review
Identity fraud	Medium	Verification

12.4 GEOGRAPHIC RISK

Region Type	Risk
Regulated jurisdictions	Low
Emerging markets	Medium
High-risk regions	High

13. INTERNAL CONTROLS

The Company maintains a system of internal controls designed to ensure effective implementation of its AML/CFT obligations and to mitigate risks associated with financial crime. Such controls include the appointment of a designated Compliance Officer responsible for overseeing the Company’s compliance framework, as well as the implementation of internal audit mechanisms to periodically assess the effectiveness of policies, procedures, and controls.

The Company further ensures that its personnel are adequately trained in AML/CFT matters and that relevant policies and procedures are regularly reviewed and updated to reflect changes in regulatory expectations, internal risk assessments, and the Company’s business activities. These internal controls form an integral part of the Company’s overall risk management and compliance structure.

14. TRAINING

The Company ensures that all employees, contractors, and relevant personnel are adequately trained in anti-money laundering and counter-terrorist financing (AML/CFT) principles and procedures. Such training is provided on a regular basis and is designed to ensure that personnel understand their obligations under this Policy, as well as their role in identifying, preventing, and reporting suspicious activities.

All personnel are required to confirm their understanding of the applicable AML/CFT requirements and to comply with internal policies and procedures. The Company further ensures that training programs are periodically updated and refreshed to reflect changes in regulatory expectations, internal risk assessments, and the evolving nature of financial crime risks.

15. MONITORING & REVIEW

This Policy is subject to periodic review in order to ensure its continued effectiveness, adequacy, and alignment with the Company’s business model and applicable regulatory expectations. The Company undertakes to review this Policy at least on an annual basis, as well as upon any material changes in applicable laws and regulations, internal risk assessments, or the nature of the Company’s operations and services.

Any amendments to this Policy shall be implemented as necessary to address identified risks, regulatory developments, or changes in the Company’s activities, and shall form an integral part of the Company’s overall compliance framework.

16. DATA PROTECTION

The Company implements appropriate technical and organizational measures to ensure the security, confidentiality, and integrity of personal data processed in the course of its operations. Such measures include, without limitation, secure data storage solutions, restricted access controls, and internal procedures designed to prevent unauthorized access, disclosure, alteration, or destruction of data.

Access to personal data is strictly limited to authorized personnel who require such access for the performance of their duties and is subject to internal access control and confidentiality obligations. The Company ensures that all individuals with access to personal data are bound by appropriate confidentiality requirements and are adequately trained in data protection principles.

The Company further undertakes to process personal data in accordance with applicable data protection laws and to implement safeguards proportionate to the nature, scope, and purpose of the processing activities. While the Company employs commercially reasonable measures to protect personal data, it acknowledges that no method of transmission over the Internet or method of electronic storage can be guaranteed to be fully secure.

17. FINAL PROVISIONS

Failure to comply with this Policy, including any obligations related to customer due diligence, transaction monitoring, or provision of requested information, may result in appropriate measures being taken by the Company. Such measures may include, without limitation, suspension or termination of services, restriction of access to the platform, internal review and disciplinary actions (where applicable), as well as reporting to relevant authorities where required by applicable laws or based on the Company’s internal risk assessment.

The Company reserves the right to take any action it deems necessary to ensure compliance with its AML/CFT obligations and to protect its operations, reputation, and users from potential financial crime risks.