Date:  19 Sep 2023

Matrixport Technologies Ltd and its affiliated entities (together referred to as ‘Matrixport’) are dedicated to actively engaging in global initiatives aimed at combating illicit activities of money laundering (ML) and the funding of terrorism (TF). Our commitment extends to ensuring strict adherence to the regulations concerning Anti-Money Laundering (AML), Countering Financing of Terrorism (CFT), and sanctions. Collectively these obligations and guidance form our AML Program.

The AML Program is put together to ensure that Matrixport complies with the applicable legislation and regulations in the countries that we operate in. This includes having adequate risk and control mechanisms to mitigate any AML/CFT risk.

The components of our AML Program encompass, among various elements:

1. AML/CFT Policy

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

a. Written policies, procedures, and internal controls designed to ensure compliance with applicable AML laws and regulations

b. Designation of a Money Laundering Reporting Officer (MLRO), who is accountable for the AML Program

c. Designation of Compliance Officers who are responsible for the day to day monitoring of AML operations

d. Robust Governance Framework where the Senior Management have oversight over the AML Program

e. Adequate Know-Your-Customer (KYC) standards to identify and verify all customers including all related parties, authorised representatives, beneficial owners where applicable. Purpose of account, source of funds, source of wealth are also obtained upon onboarding

f. Risk assessments of clients are performed based on client types, industries, jurisdictions and products offered

g. Enhanced due diligence are conducted for customers who have been identified as presenting higher risk, including those who are assessed to have Politically Exposed Person (PEP) nexus, High Risk Industries, Adverse news or any other risk elevating factors as detected through our ongoing compliance effort such as Know Your Transactions (KYT) or Transaction Monitoring (TM)

h. Escalating and filing of suspicious activities internally and externally with the relevant regulatory authorities

i. Periodic Reviews (PR) are conducted based on the risk rating of customers

j. Annual mandatory AML/CFT training is required for all employees, all new joiners are required to complete the AML/CFT training

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

l. Maintenance of client records according to the period prescribed by the relevant authorities

2. Prohibited Uses, Customers and Businesses

a. Prohibited Business Relationships
Matrixport shall not conduct business relationships with the following client types:

• Sanctioned individuals and entities by the BVI authorities or under International Sanctions lists (e.g. United Nations Security Council, United States Office of Foreign Asset Control (OFAC), EU Sanctions, Singapore Monetary Authority of Singapore lists etc);
• Business enterprises and persons which it knows or must presume to be involved in terrorist financing or to be a criminal organisation or belong to or support such an organisation;
• Shell banks which have no physical presence at their place of incorporation
• Clients operating under fictitious names or pseudonyms
• Clients that are in Weapons, Armament Manufacturers, Armament Trading
• Clients involved in Tobacco trading
• Clients involved in Adult Entertainment
• Clients involved in Casinos, Gambling or similar industries

b. Prohibited Assets
Matrixport shall not allow funds, of which it knows via its Know Your Transaction (KYT) monitoring or KYC checks to be the proceeds of a crime or to be used for financing terrorism or belonging to a criminal organisation, to enter into a client business relationship, even if the crime or offence was committed abroad.

c. Restricted Jurisdictions
Matrixport shall not enter business relationships with clients from restricted jurisdictions. This includes but is not limited to jurisdictions with sanctions nexus, severe political instability and/or economic inequality. A detailed list is to be found on https://support.matrixport.com/hc/en-us/articles/360039268014-Matrixport-Restricted-Countries and is subjected to annual review.

3. KYT at Matrixport

Matrixport strictly prohibits users from using our platforms to engage in illegal activities such as money laundering, terrorist financing or illegal commerce.

Real time and continuous KYT screening is performed on all users’ transactions. In case of any suspected illegal transactions or illegal acts found through KYT and transaction monitoring, Matrixport may take actions against the user, including but not limited to rejecting funds, issuing request for information, freezing accounts or reporting of suspicious activity to appropriate regulatory authorities. Matrixport reserves all rights under its contractual arrangements with you and under the laws applicable to it.

4. Prohibited Activity

Matrixport would like to remind users of prohibited actions at our platforms, including but not limited to:

• Transactions that may violate, or cause Matrixport to violate applicable economic sanctions imposed or enforced by various governmental agencies including, but not limited to, those administered by the Office of Foreign Asset Control of the U.S. Department of Treasury, U.S. Department of State, the United Nations Security Council, the European Union member state, His Majesty's Treasury of the United Kingdom, the Monetary Authority of Singapore and etc. Matrixport is committed to combatting financial crime and complying with all applicable sanctions laws and regulations in the jurisdictions in which we operate.
• Transactions related to illicit activities, such as frauds, scam, stolen funds, ransomware, malware.
• Transactions related to risky activities, such as mixing, darknet markets.
• Transactions related to casinos, gambling or similar industries.
• Transactions with irregular, unusual or uncommon transaction patterns and no logical business explanation, such as deposit followed by almost immediate withdrawal without additional activity.