Anti-Money Laundering Policy

AML Policy

This Anti-Money Laundering and Counter-Financing of Terrorism (“AML/CFT”) Programme is adopted by Nodex Global Limited (“Company”) on a voluntary and precautionary basis. Although the Company’s non-custodial software platform may not fall within the scope of financial-services licensing requirements under current British Virgin Islands legislation, the Company chooses to follow the AML/CFT standards recommended by the Financial Action Task Force (FATF) and applicable guidance issued in the British Virgin Islands and other relevant jurisdictions.

The AML Program is designed to ensure Company complies with the above mentioned requirements and obligations set out in the applicable British Virgin Islands legislation, regulations, rules and industry guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate the risk of the company being used to facilitate financial crime.

1. AML/CFT and Sanctions Policy

   The AML/CFT and Sanctions Policy sets out the minimum standards which must be complied with by us. This includes:

   1. Robust Governance Framework in which the Board of Directors (the “Board”) and Senior Management provide oversight over the AML Program;

   2. Designation of a Money Laundering Reporting Officer (“MLRO”), who is accountable for the design and operations of the AML Program. The MLRO has unfettered direct access to, and regular communication with the Board and Senior Management, and provides them with regular reports on the operations and effectiveness of Company’s AML Program;

   3. Designations of Compliance Officers who are responsible for coordinating and monitoring day to day compliance with the AML Program;

   4. AML risk assessments at the AML Program, customer and product & services levels;

   5. Written policies, procedures, and a system of internal controls designed to facilitate ongoing compliance with applicable AML laws and regulations;

   6. Know-Your-Customer (“KYC”) Standards reasonably designed to identify and verify all customers and, where applicable, beneficial owners, source of funds and the nature and intended purpose of the business relationship, to the extent warranted by the risk of ML or TF or as required by regulations;

   7. Enhanced due diligence for those customers presenting higher risk, including those who are assessed to have Politically Exposed Person (“PEP”) nexus;

   8. Having a combination of risk-based measures and systems for monitoring transaction activity through customers' accounts, and contacting users for additional information as and when necessary, where such information is not available from monitoring and analysis, to ensure compliance with applicable laws, regulations and policies;

   9. Procedures to report unusual activities internally, and reporting of suspicious activity to appropriate regulatory authorities in accordance with applicable laws;

   10. Mandatory, periodic AML training for appropriate personnel;

   11. Independent audit to review and assess the compliance with the AML Program;

   12. The maintenance of appropriate records for the minimum prescribed periods; and

   13. Company is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. In addition to the local MAS List, we endeavor to screen against the United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (“OFAC”), and other sanctions watchlist in the jurisdiction(s) in which we operate.

2. Prohibited Uses, Customers and Businesses

   1. Prohibited Uses Company does not permit users to engage in the categories of illegal manners which includes but not limited to fraud and money laundering.

   2. Prohibited Customers and Business Company prohibits conducting business with certain categories of clients, including but not limited to:

      1. Individuals or entities known or suspected to be a terrorist or a criminal organisation or member of such or listed on sanction lists;

      2. Clients operating in prohibited industries listed in 2(a.) above;

      3. Client in which their identity, or beneficial owners cannot be ascertained;

      4. Clients who refuse to furnish information or documents to satisfy our level of due diligence; and

      5. Clients where the legitimacy of the business cannot be ascertained.

      Compliance with our AML Program and internal procedures allows us to maintain a good standing in the jurisdictions in which we transact business. Company cooperates to the fullest extent permitted by law with investigations and inquiries from law enforcement and regulatory authorities.