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Know Your Business (KYB) Policy

January 17, 2025

Introduction

The Know Your Business (KYB) Policy is part of NEW CRYPTO ERA II S.A.S. DE C.V.’s

Anti-Money Laundering (AML) programs, implemented to comply with applicable AML/KYC regulations. KYB focuses specifically on conducting comprehensive due diligence of businesses we intend to onboard as clients. By verifying the identity and authenticity of enterprises and organizations during the KYB process, we cross-check business data against our internal KYB standards. NEW CRYPTO ERA II S.A.S. DE C.V. is committed to preventing illegal activity. The purpose of KYB is identity verification, fraud prevention, and anti-money laundering enforcement.

Each applicant undergoes the KYB procedure as follows: •The applicant uploads corporate and beneficial ownership data. •NEW CRYPTO ERA II S.A.S. DE C.V. conducts document review, ownership structure checks, registry validations, AML screening, and automated KYC checks of beneficial owners. •NEW CRYPTO ERA II S.A.S. DE C.V.’s legal team reviews the KYB outcomes. •Each applicant receives an informative report at the conclusion of the KYB process.

The KYB procedures involve collecting and analyzing various data points. Core elements include:

1. Business Identity Verification

This step validates the legal existence and legitimacy of the business by reviewing its registration or licensing documents. It helps ensure we are engaging with a legally recognized business and not a fraudulent entity. Required information includes: •Name – Registered legal business name. •Address – Operational business address(es), which may differ from the registered address. •Tax Identification Number (TIN) – For US-based entities, this is generally the Employer Identification Number (EIN), used for opening bank accounts, filing tax returns, and identity verification. •Business Registration Status – All businesses must provide a Certificate of Incorporation or Registration. •Licensing Documentation – Operating licenses where applicable (note: not all businesses require a license)

2. Identification of Directors and Owners

•Document verification. •Ultimate Beneficial Ownership (UBO) determination and verification

3. Transaction Monitoring

Certain transactional behaviors may indicate involvement in money laundering or terrorism financing. Red flags include: •Unusual transaction frequency or volume. •Transactions just below regulatory thresholds. •Transactions involving high-risk jurisdictions

4. Sanctions Screening

Businesses and their personnel are checked against global sanctions lists, including: •OFAC Sanctions List. •UN Sanctions List. •EU Sanctions List

5. PEP Screening

Businesses potentially exposed to political corruption may pose heightened AML risks. We therefore screen for Politically Exposed Person (PEP) status.

6. Adverse Media Monitoring

We track businesses for their appearance in negative or adverse media coverage indicating possible involvement in criminal activity. Continuous monitoring includes traditional media and online sources.

Business Registration

During business onboarding, KYB verification serves as a first line of defense against fraudulent entities. After initial registration, in-depth KYB checks are performed. These include: •Verification of physical business addresses •Verification of official business phone numbers •Identification of funding sources. Collected information is cross-referenced for accuracy and used to perform a risk assessment evaluating the potential risk of the business partnership.

Ongoing Client Monitoring

The final step of KYC involves monitoring the client account for suspicious activity, including: •Unusual transaction patterns •Large or frequent transactions inconsistent with the client’s profile

NEW CRYPTO ERA II S.A.S. DE C.V.’s KYB procedures ensure the company does not engage in business with entities involved in:

•Money laundering •Terrorism financing •Tax crimes •Sanctions violations •Fraud or other financial crimes

If you have any questions, please contact us at: info@aifory.pro