KYC AND AML POLICY

ANTI-MONEY LAUNDERING (“AML”) / KNOW YOUR CUSTOMER (“KYC”) POLICY (hereinafter the “Policy”)

1. Introduction

KAIRON LABS BV (hereinafter “KAIRON LABS”) is a company specialized in software-based algorithmic liquidity provision for cryptographic markets, and therefore recognizes the critical importance of combating money laundering, terrorism financing, and other illicit activities. This Policy is designed to establish standard procedures and controls with regard to the applicable regulation to combat any adverse effect of such activities on the integrity of the (cryptographic) markets. This Policy applies to all employees, stakeholders, contractors and clients of KAIRON LABS.

2. Objectives

The purpose of this Policy is to establish a general framework for the fight against money laundering, terrorism financing and other illicit activities. In particular, the objectives of this Policy are to (i) prevent the use of KAIRON LABS’ services for money laundering, terrorism financing, or any other illicit activities, (ii) to identify and mitigate potential risks associated with money laundering, terrorism financing or any other illicit activities, (iii) to ensure and maintain the integrity of KAIRON LABS’ operations and reputation, and (iv) to ensure compliance with all applicable AML/KYC laws, regulations and guidelines.

3. Governance

KAIRON LABS has appointed a responsible person at the “highest level” among its directors for the prevention of money laundering, terrorism financing, and other illicit activities.

4. Minimum Standards

KAIRON LABS, to the best of its efforts, assesses the risks of money laundering, terrorism financing and other illicit activities, taking into account risk factors relating to their clients, countries or geographic areas, products, services, transactions and delivery channels. Therefore, KAIRON LABS has established certain standards to identify our clients before entering into a business relationship.

4.1. Client Due Diligence

4.1.1. Client Identification

KAIRON LABS shall collect comprehensive information to accurately identify and verify the identity of all clients as follows by using https://kyc-chain.com :

For individuals, this includes obtaining the following:

• full legal name
• date of birth
• nationality
• residential address
• government-issued identification document
• Proof of liveliness
• Basis information source of wealth
• …

For legal entities, this includes obtaining the following:

• Legal name
• Registration number
• Registered address
• Official documentation relating to the legal status of the company (articles of association, incorporation certificate…)
• Beneficial ownership structure
• Director structure
• Identification of shareholders and directors
• Relevant legal opinions relating to the client’s project
• …

4.1.2. Individual Risk Assessment

The factors taken into account for the individual risk assessment and classification (high-medium-low) of our clients on a risk-sensitive basis are the ones that are as follows : (i) delivery channel risk, (ii) product, service or transaction risk, (iii) client risk, and (iv) geographical risk, bearing in mind the inherent risk nature and business standards of the cryptographic markets.

4.1.3. Enhanced Due Diligence

For clients presenting higher risks, KAIRON LABS will conduct enhanced due diligence procedures, which may include obtaining additional information, enhanced monitoring, and seeking management approval for engaging in any business relationship.

Examples of risk factors that may trigger enhanced due diligence could include : (i) the home country or country of residence or registration, (ii) the country of birth or incorporation; (iii) the nationality, (iv) the profession, (v) the economic activity, (vi) the appearance on sanction lists; (vii) the PEP-status (politically exposed persons) of clients, representatives and beneficial owners, (viii) the delivery channel (face-to-face or remotely with or without safeguards), (ix) the source of wealth, (x) the type of client, (xi) the type and size of payments that could be expected; (xii) the reputation of the client in relation to the cryptographic market…

4.1.3.1. Enhanced Due Diligence Measures

1. Source of Funds and Wealth

KAIRON LABS will request thorough information relating to the source of funds or wealth of clients, particularly those presenting higher risk. This may include requesting documentation such as bank statements, trade history, token deployment contracts, token distribution models and solutions, business financial records… If needed, further verification of the legitimacy of the client's source of funds or wealth will be undertaken to ensure they are consistent with their declared financial activities and registrations.

1. Business Relationships

For clients establishing business relationships involving transactions with high-value assets, complex ownership structures, or involving jurisdictions known for higher levels of financial crime, in-depth background checks may be conducted on beneficial owners, senior management, and other associated parties to assess their reputability and potential risk factors and they may be requested to provide any and all relevant information to mitigate any risks.

4.2. Ongoing Monitoring

Periodic and risk-based reviews are carried out to ensure that client-related documents, data or information are kept up-to-date. For clients presenting higher risk, enhanced ongoing monitoring will be conducted. This includes regular reviews of client activity, transaction patterns, and any changes in risk factors. Any significant changes in the client's profile or behavior will trigger a reassessment of the client's risk rating and the application of additional due diligence measures as necessary.

5. Monitoring of Transactions

KAIRON LABS implements transaction monitoring systems and processes to detect and investigate suspicious activities using https://www.chainalysis.com/. Transaction monitoring could include the following : (i) real-time monitoring of transactions for unusual patterns, large, complex or inconsistent transactions, (ii) retrospective analysis of transactions to identify potentially suspicious activity, (iii) regular reviews of transaction logs and reports.

6. Record Keeping

Records of personal data obtained for the purposes of the prevention of money laundering and terrorism financing or other illicit activities are processed and kept in accordance with the requirements from the EU General Data Protection Regulation (GDPR) and shall not be further processed in a way that is incompatible with those purposes.

7. Internal Measures

7.1. Reporting

Suspicious transactions will be reported in compliance with the respective laws and regulations by means of the responsible person. Issues and activity reports are reviewed on a regular basis. The quality of coverage of the internal control will be reviewed on a regular basis.

7.2. Training

KAIRON LABS will provide regular training and awareness programs to all employees to ensure they understand their AML/KYC obligations and are equipped to identify and report suspicious activities effectively.

8. Conclusion

KAIRON LABS is committed to maintaining the highest standards of integrity. This policy reflects our dedication to preventing illicit activities and protecting the integrity of our operations. All employees, stakeholders, contractors and clients are expected to adhere strictly to the provisions of this Policy.

This AML/KYC Policy will be reviewed periodically and updated as necessary to reflect changes in laws, regulations, and industry best practices.