AiFory LLC Anti-Money Laundering and Know Your Customer Policy (hereinafter - the "AML/KYC Policy") is designated to prevent and mitigate possible risks of AiFory LLC being involved in any kind of illegal activity. Both international and local regulations require AiFory LLC to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users. AML/KYC Policy covers the following matters: Verification procedures. Sanctions and PEP lists screening. Compliance Officer. Monitoring Transactions. Risk Assessment.

One of the international standards for preventing illegal activity is customer due diligence ("CDD"). According to CDD, AiFory LLC establishes its own verification procedures within the standards of anti-money laundering and "Know Your Customer'' frameworks. Identity verification AiFory LLC 's identity verification procedure requires the User to provide AiFory LLC with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes AiFory LLC reserves the right to collect User's identification information for the AML/KYC Policy purposes. AiFory LLC will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and AiFory LLC reserves the right to investigate certain Users who have been determined to be risky or suspicious. AiFory LLC reserves the right to verify User's identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, AiFory LLC reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past. User's identification information will be collected, stored, shared and protected strictly in accordance with the AiFory LLC 's Privacy Policy and related regulations. Identity verification procedure includes the following steps: Automated ID Verification Facial Recognition Synchronization with National Government Registries Automated ID Verification Identity verification software automatically recognizes, verifies and extracts information from more than 3000 identity documents across more than 190 countries. From passports and ID cards to driving licenses and residence permits, conduct efficient and accurate identity document analysis on a global scale. Facial Recognition, 3D Liveness Detection and Authentication Advanced biometric and face recognition algorithms ensure that the faces analyzed are real and prevent the use of pictures of faces, 3D masks, and other fakes or renderings in the identity verification process. Three-dimensional face maps can be utilized as bulletproof user authentication and login methods. Synchronization with National Government Registries Identity verification software automatically reverifies information taken from ID documents with government databases of more than 70 countries, providing an extra level of security. Once the User's identity has been verified, AiFory LLC is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity. Card verification The Users who are intended to use payment cards in connection with the AiFory LLC's Services have to pass card verification in accordance with instructions available on the AiFory LLC 's Site. Strictly Prohibited and the appropriate rights of Aifory Pro (1) to pass the access to the personal account to a third party (2) the following activities: (a) Money laundering; (b) Financing terrorism, including to transfer funds to terrorist organizations and/or to support their activities; (c) Fraud activity, including phishing, credit card fraud, fraudulent schemes and other illegal activities related to the illegal receipt of funds by fraudulent means; (d) Drug trafficking including to settle the purchase and sale of drugs; (e) Arms trafficking including to settle the purchase and sale of weapons; (f) Providing cryptocurrency exchange services for third parties; (g) Providing fiat currency exchange services for third parties; (h) Using Aifory Pro for any business settlements as deviation from any regulation: any activity aimed at deviating from the requirements and procedures, established policies and rules of Aifory Pro; (3) In the event of suspicious transactions by the User, Aifory Pro shall be entitle to freeze the User's balance; (4) Aifory Pro is empowered if it is required to request any necessary information and documents from any User, including to pass video verification, the User undertakes to present and comply with all the requested information; (5) To replenish the personal User’s account of the Aifory Pro User must use only bank cards, to be loyal to Aifory Pro and disclosure of his name, if required; (6) Any User is obliged to provide complete and reliable information when carrying out KYC procedures.

AiFory LLC screens applicants against recognised Sanctions and Politically Exposed Persons (PEPs) lists. Individuals and legal entities are screened against mentioned lists: on the onboarding stage when the user is submitting the application; on each anti-fraud and AML alerts manually by Compliance Officer; monthly by running automatically with a script to re-check all DB of customers. Checking process includes the following steps: International Sanctions Lists monitoring. Law enforcement watchlists Monitoring International Sanctions Lists monitoring: International Sanctions Lists include the following databases: OFAC-SDN FSE (OFAC Consolidated: FSE, SSI, Palestinians, Non-SON) OICV-IOSCO World Bank United, Nations - Consolidated sanctions list United Nations - Development SECO - Sanctions & Embargos United Kingdom HM Treasury Consolidated Registre des gels des avoirs (Consolidated with UN) European Union - Consolidated list of sanctions The Central Bank of the Russian Federation Rosfin Monitoring Russia Interpol Law enforcement watchlists Monitoring Law enforcement watchlists include the following databases: Europol: Europe Most Wanted Most Wanted of United Kingdom - National Crime Agency (NGA) FBI U.S. Food & Drug Administration Financial Crime Enforcement Network- 311 Special Measures

The Compliance Officer is the person, duly authorized by AiFory LLC, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer's responsibility to supervise all aspects of AiFory LLC 's anti-money laundering and counter-terrorist financing, including but not limited to: Collecting Users' identification information. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations. Monitoring transactions and investigating any significant deviations from normal activity. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs. Updating risk assessment regularly. Providing law enforcement with information as required under the applicable laws and regulations. The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity. The Compliance Officer is Giorgi Nutsubidze.

The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, AiFory LLC relies on data analysis as a risk-assessment and suspicion detection tool. AiFory LLC performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include: Daily checking Users against recognized "black lists" (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable; Case and document management. Fully automated transaction monitoring tools prevent criminal activity is often known as "dirty" money, such as money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users. Transaction monitoring software analyzes automatically incoming and outgoing data. With regard to the AML/KYC Policy, AiFory LLC will monitor all transactions and it reserves the right to: ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer; request the User to provide any additional information and documents in case of suspicious transactions; suspend or terminate User's Account when AiFory LLC has reasonably suspicion that such User engaged in illegal activity. The above list is not exhaustive and the Compliance Officer will monitor Users' transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

AiFory LLC in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, AiFory LLC is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention. If you have any questions, please contact us at the following contacts: [email protected]