Anti-Money Laundering Policy (AML)

Sendico adheres to a strict anti-money laundering (AML) and counter-terrorism financing (CFT) policy in accordance with international standards and local legislation requirements. We will not facilitate illegal transactions or activities related to money laundering. Our company is fully committed to creating a secure financial environment and preventing the use of our platform for illegal purposes. Our AML/CFT program is based on FATF (Financial Action Task Force) recommendations and best practices in the fintech industry.

We regularly conduct assessments of money laundering and terrorism financing risks related to our activities, clients, countries of presence, and provided services. Our risk assessment considers the following factors: Client-related risks: - Type of client (legal entity, individual entrepreneur) - Business sector and business model - Ownership structure and beneficial owners - Reputation and business relationship history Geographic risks: - Countries with high corruption levels - Jurisdictions not complying with international AML/CFT standards - Countries under sanctions - Offshore zones Product and service risks: - Type and volume of transactions - Methods of funding and withdrawal - Use of cryptocurrencies - Anonymous payment instruments Based on this assessment, we apply appropriate control measures and establish verification levels for each client.

We conduct thorough verification of all clients (Customer Due Diligence - CDD) before establishing business relationships. Standard customer verification includes: Client identification: - Obtaining and verifying identity documents - Confirming legal status of organization - Verifying contact information - Address verification Beneficial owner verification: - Identifying individuals owning more than 25% of shares or votes - Determining persons exercising control otherwise - Obtaining documents confirming beneficiary identity Understanding business nature: - Client activity description - Income sources and origin of funds - Expected nature and volume of transactions - Purpose of business relationship List checking: - Checking client and beneficiaries against sanctions lists - Checking for politically exposed persons (PEP) status - Checking for negative media information All collected information is documented and regularly updated.

For high-risk clients, we apply enhanced verification measures (Enhanced Due Diligence - EDD). Enhanced verification applies to: Politically Exposed Persons (PEP): - High-ranking government officials - Members of parliament and judges - Heads of state-owned companies - Family members and close partners of PEP Clients from high-risk countries: - Countries included in FATF lists - Jurisdictions with insufficient AML/CFT regulation - Countries under international sanctions Companies with complex structures: - Multi-level holding structures - Companies with nominee directors or shareholders - Trusts and other complex legal entities Clients with high transaction volumes: - Clients exceeding established threshold values - Unusually high activity for business type Enhanced verification measures include: - Obtaining additional information about sources of funds - In-depth study of business model - Senior management approval - Enhanced monitoring of all transactions - More frequent client information updates

We conduct continuous monitoring of all transactions to identify suspicious activity. Our monitoring system: Automated analysis: - Use of machine learning algorithms - Detection of atypical transaction patterns - Automatic alerts for suspicious activity - Real-time analysis Signs of suspicious activity: - Transactions not matching client profile - Unusually large or frequent operations - Splitting large amounts into multiple small transactions (structuring) - Transactions involving high-risk countries - Convoluted payment schemes without economic sense - Operations shortly after registration or long inactivity period Manual analysis: - Alert verification by compliance specialists - Investigation of suspicious cases - Requesting additional information from client - Documenting verification results All suspicious transactions are registered and analyzed. Information is transmitted to appropriate authorities when necessary.

If we identify suspicious activity, we are obligated to report it to appropriate regulatory authorities. Examples of suspicious activity: Atypical client behavior: - Refusal to provide requested information or documents - Providing false or misleading information - Unusual secrecy regarding business activities - Excessive concern about confidentiality issues Suspicious transactions: - Transactions without obvious business or legal purpose - Funds from unknown sources - Rapid movement of funds through accounts - Transactions structured to avoid reporting Connection to criminal activity: - Connection to known criminals or criminal organizations - Transactions related to investigated crimes - Information about possible involvement in illegal activities Reporting procedure: - Documenting all facts and circumstances - Preparing Suspicious Activity Report (SAR) - Submitting report to relevant authority - Complying with reporting deadlines established by legislation Important: We do not notify clients that a suspicious activity report has been filed about them (tipping off principle).

We store all records related to client identification and transactions for the period established by legislation. Stored records include: Identification documents: - Copies of identity documents - Legal entity registration documents - Beneficial owner information - Address documents Transaction information: - Details of all transactions (date, amount, sender, recipient) - Payment purpose - Payment method - Supporting documents Verification documentation: - Customer verification results (CDD/EDD) - Risk analysis - Decisions on establishing business relationships - Transaction monitoring results Correspondence: - Requests for additional information - Client responses - Internal compliance correspondence Retention periods: - Identification documents: minimum 5 years after termination of business relationship - Transaction records: minimum 5 years after transaction - Suspicious activity reports: minimum 5 years after submission All records are stored securely and available for review by regulatory authorities upon request.

All Sendico employees undergo regular AML/CFT training. We ensure our team is aware of the latest trends in money laundering and terrorism financing. Training program includes: Introductory training: - Basics of anti-money laundering legislation - Company policies and procedures - Signs of suspicious activity - Employee responsibilities Regular training: - Annual advanced courses - Updates on legislation or procedure changes - Practical case analysis - New money laundering and fraud methods Specialized training: - In-depth training for compliance department staff - Risk-specific training for different departments - Participation in industry conferences and seminars Testing: - Knowledge checks after training - Periodic employee certification - Documentation of training results All employees are required to report any suspicions regarding money laundering or terrorism financing to the responsible compliance officer.

We check all clients and payment recipients against international sanctions lists. We will not conduct transactions with sanctioned persons or organizations. Checked lists: International sanctions lists: - UN sanctions list - OFAC (Office of Foreign Assets Control) list - European Union sanctions lists - Lists of other countries and international organizations National lists: - Lists of organizations and individuals with information about involvement in extremist activities or terrorism - Lists of terrorist organizations Verification procedure: - Automatic check during registration - Payment recipient check before transaction processing - Regular check of existing clients (at least quarterly) - Immediate check when sanctions lists are updated Actions upon match: - Immediate account or transaction blocking - Notification of appropriate authorities - Freezing funds according to legislative requirements - Documentation of all actions We also monitor compliance with sectoral and territorial sanctions prohibiting certain types of transactions or activities.

We will not process payments related to certain activities that present high money laundering risk or are illegal. Prohibited activities include: Illegal trade: - Trading weapons, ammunition without appropriate licenses - Drug and psychotropic substance trafficking - Human trafficking - Organ trafficking - Counterfeit product trade Financial crimes: - Money laundering - Terrorism financing - Fraud and embezzlement - Tax evasion - Pyramid and Ponzi schemes Sanctions violations: - Transactions with sanctioned persons or organizations - Operations violating sectoral or territorial sanctions - Circumventing sanction restrictions Other illegal activities: - Financing extremist activities - Cybercrime - Bribery and corruption - Illegal gambling activities - Any other activities prohibited by legislation If we discover a client is using the platform for prohibited activities, we will immediately terminate service, block the account, and report to appropriate authorities.

We fully cooperate with law enforcement and regulatory authorities, providing all necessary information upon request in accordance with applicable legislation. Our cooperation includes: Providing information: - Timely responses to regulatory authority requests - Providing documents and records - Access to transaction and client data - Explaining our policies and procedures Reporting: - Submitting mandatory reports within deadlines - Suspicious Activity Reports (SAR) - Currency transaction reports - Other reports required by legislation Inspections and audits: - Facilitating inspections - Providing access to premises and systems - Cooperating with auditors Complying with directives: - Immediate execution of regulatory directives - Eliminating identified violations - Implementing recommendations for procedure improvements We guarantee confidentiality of information provided to regulatory authorities and do not disclose the fact of such cooperation to clients when prohibited by law.

This AML Policy is regularly reviewed and updated considering changes in legislation, regulatory requirements, and industry best practices. Review process: Regular review: - Annual scheduled policy review - Assessment of existing procedure effectiveness - Analysis of identified deficiencies and incidents - Updates considering new risks and threats Unscheduled review: - Upon changes in legislation or regulatory requirements - After significant changes in business model - In case of identified serious procedure deficiencies - Upon recommendations from regulators or auditors Approving changes: - Change approval by company management - Documentation of changes made - Notifying employees of updates - Training personnel on new procedures We are committed to continuous improvement of our AML/CFT procedures to ensure maximum protection against money laundering and terrorism financing.

For questions related to AML policy, contact our compliance specialist: AML/CFT Compliance Officer Email: compliance@sendico.com Address: Moscow, Russian Federation Phone: +7 (495) XXX-XX-XX For reporting suspicious activity: Email: suspicious@sendico.com (confidential) All reports are handled confidentially. We guarantee protection for persons reporting suspicious activity in good faith.