AML Policy

Tradever is committed to the prevention and active deterrence of money laundering and the financing of terrorism. This AML Policy outlines the principles, procedures, and internal controls that Tradever follows to detect, prevent, and report potential money laundering or terrorist financing activities in accordance with international best practices.

Tradever's AML Policy aims to:

• Establish clear and comprehensive guidelines to prevent money laundering and terrorist financing.
• Ensure compliance with all applicable AML and counter-terrorism financing laws and regulations.
• Promote awareness and understanding among all staff and partners of their AML responsibilities.
• Maintain transparent and ethical business practices at every operational level.

Under this policy, money laundering typically includes one or more of the following activities:

• Converting, transferring, or moving illicit proceeds to conceal their origin or to assist someone involved in generating such proceeds.
• Concealing or disguising the true nature, source, location, disposition, movement, or ownership of illicit funds.
• Acquiring, possessing, or using property with the knowledge that it originated from criminal activity.
• Participating, assisting, or attempting to participate in any of the above acts.

Tradever strictly prohibits any activity that may facilitate money laundering, directly or indirectly.

Money laundering generally takes place in three stages:

1. Placement — introducing illicit funds into the financial system.
2. Layering — disguising the source of funds through complex transactions.
3. Integration — reintroducing the laundered money into the economy as apparently legitimate funds.

Terrorist financing involves the collection or provision of funds with the intention that they be used to carry out acts of terrorism. Unlike money laundering, the funds used for terrorism may originate from both legal and illegal sources.

Common patterns include:

• Using legal business structures to fund or conceal terrorist activities.
• Misusing charitable organizations for funding extremist operations.
• Transferring money across borders to finance terrorism.

Tradever implements rigorous controls to identify and prevent any transaction that may be connected to terrorist financing.

Our AML framework aligns with globally recognized laws and standards, including but not limited to:

• The Financial Action Task Force (FATF) Recommendations.
• The USA PATRIOT Act and Bank Secrecy Act (BSA).
• The European Union Anti-Money Laundering Directives (AMLD).
• United Nations Security Council Resolutions related to counter-terrorism financing.

Tradever continuously reviews these frameworks to ensure full compliance with international and local AML regulations.

Tradever strictly prohibits clients and employees from engaging in or facilitating any of the following activities:

• Accepting funds derived from illegal activities.
• Structuring transactions to evade reporting requirements.
• Opening or maintaining anonymous or fictitious accounts.
• Using third-party accounts or intermediaries to disguise the origin of funds.

Any violation of these prohibitions will result in immediate investigation and potential termination of the relationship.

Tradever fully cooperates with regulatory and law enforcement authorities by providing timely and accurate information as required under applicable AML laws.

Employees who report suspicious activities in good faith are protected by Tradever's whistleblower policy and relevant legal safeguards.

No disciplinary or legal action will be taken against employees who, acting in good faith, submit a suspicious activity report.

Tradever continuously monitors customer activity to detect unusual or suspicious transactions. These include, but are not limited to:

• Unusually large transactions inconsistent with a client's typical behavior.
• Frequent deposits or withdrawals without a clear legitimate purpose.
• Transfers involving high-risk jurisdictions or offshore centers.
• Structuring transactions to avoid reporting thresholds.

Tradever has implemented robust systems and tools to identify suspicious activities and mitigate AML risks. We apply both automated and manual review processes to flag irregular patterns, ensuring continuous vigilance.

• Identity verification (Know Your Customer — KYC).
• Risk-based transaction monitoring.
• Screening against global sanctions and watchlists.
• Ongoing review of client behavior and account activity.

Reports submitted to the Compliance Officer should include:

• Description of the suspicious transaction or activity.
• Identification details of the involved client(s).
• Any supporting documentation or evidence.
• Date, time, and method of detection.

Tradever maintains complete and accurate records of client identification and transaction history to support investigations if necessary.

• Customer identification documents.
• Transaction records and communications.
• Suspicious activity reports (SARs).
• Internal compliance and training logs.

All records are securely stored and retained for a minimum of five (5) years, or longer when required by law.

Tradever regularly evaluates its AML risk exposure to adapt its controls accordingly.

• Assessing geographical risk factors.
• Analyzing client profiles and transaction patterns.
• Monitoring new products and delivery channels.
• Reviewing third-party service providers and affiliates.

Our risk-based approach allows us to allocate resources efficiently while maintaining full regulatory compliance.

Screening is performed against, at minimum:

• Office of Foreign Assets Control (OFAC).
• European Union Sanctions List.
• United Nations Security Council Sanctions List.
• Her Majesty's Treasury (HMT) Consolidated List.

Failure to comply with this AML Policy may result in severe legal and disciplinary consequences, including:

• Termination of employment or business relationships.
• Administrative fines or civil penalties.
• Criminal prosecution for willful violations.
• Reputational damage to Tradever and its partners.

Tradever enforces a zero-tolerance policy for AML breaches.

All employees are personally responsible for adhering to AML requirements and must:

• Complete AML training and certification programs.
• Identify and verify customers in compliance with KYC procedures.
• Report suspicious activities immediately.
• Maintain confidentiality of all compliance-related information.

Tradever does not engage with shell banks or institutions that allow anonymous accounts.

• We refuse to maintain correspondent relationships with shell banks.
• We prohibit any transaction involving anonymous or fictitious accounts.
• We require full transparency in all banking and payment operations.

Tradever ensures that all employees are trained and aware of AML regulations and their responsibilities under this policy. Initial training covers AML fundamentals, red flags, and proper reporting channels.

Employees learn to identify suspicious behavior, use internal reporting systems, and protect customer data. Ongoing refresher sessions reinforce best practices and regulatory updates through:

• Annual AML refresher courses.
• Scenario-based workshops.
• Briefings on new KYC and sanctions rules.

Tradever maintains full training records for auditing and compliance verification purposes.

The Compliance Department monitors the implementation and enforcement of this AML Policy, ensuring all internal processes, systems, and third-party relationships meet AML standards.

Its responsibilities include:

• Conducting internal audits.
• Updating AML procedures as laws evolve.
• Reporting to senior management.
• Liaising with regulators when necessary.

Through continuous review and enforcement, Tradever maintains transparent, effective, and compliant AML practices.