The Company designates a Compliance Officer who is responsible for overseeing and enforcing the AML policy, ensuring its implementation, and acting as the point of contact for any AML-related matters.

Customer Identification: The Company conducts thorough customer identification procedures for all clients, including individuals and businesses. This includes obtaining and verifying information such as name, address, date of birth, identification documents, and, where applicable, beneficial ownership information.

Risk Assessment: The Company assesses the risk associated with each customer based on factors such as the nature of the customer's business, country of origin, transactional patterns, and any other relevant risk indicators. Enhanced due diligence measures are applied to high-risk customers.

Politically Exposed Persons (PEPs): The Company implements enhanced due diligence procedures for customers who are identified as PEPs, including conducting additional verification and ongoing monitoring of their activities.

Transaction Monitoring: The Company maintains a robust system for monitoring and analyzing customer transactions to detect any suspicious or unusual activities. This includes the use of automated monitoring tools, transactional analysis, and pattern recognition techniques. Any transactions that raise suspicions of money laundering or terrorist financing are promptly reported to the relevant authorities.

Record Keeping: The Company maintains accurate and up-to-date records of all customer transactions, including identification documents, transaction details, and any other relevant information. These records are securely stored and made available to regulatory authorities upon request.

Training and Awareness: The Company provides regular training to its employees to ensure they are knowledgeable about AML laws, regulations, and procedures. This training includes recognizing and reporting suspicious activities, understanding customer due diligence requirements, and staying updated on emerging trends and typologies related to money laundering and terrorist financing.

Reporting Suspicious Activities: The Company has a duty to report any suspicious activities to the appropriate authorities as required by applicable laws and regulations. The Compliance Officer ensures that all suspicious activity reports (SARs) are prepared accurately and submitted in a timely manner.

Independent Audits: The Company conducts periodic independent audits of its AML procedures and controls to assess their effectiveness and identify areas for improvement. These audits may be conducted by internal or external auditors.

Cooperation with Authorities: The Company cooperates fully with relevant regulatory and law enforcement authorities in their efforts to combat money laundering and terrorist financing. This includes providing requested information, assisting in investigations, and maintaining open lines of communication.

Ongoing Monitoring and Review: The AML policy and procedures of the Company are regularly reviewed and updated to reflect changes in laws, regulations, and industry best practices. This ensures that the Company remains proactive in addressing emerging risks and maintaining compliance with evolving AML requirements.

This AML Policy of Easy Tender Technologies Limited is an integral part of the company's commitment to maintaining a secure and transparent financial environment and preventing the misuse of its services for illicit activities.