All capitalized terms not otherwise defined in this document shall have the meanings ascribed to them in the Terms and Conditions.

Money Laundering is the process of disguising the origin of the proceeds of crime. Terrorist financing provides funds for terrorist activity. The use of products and services by money launderers and terrorists exposes Agaminn to significant criminal, regulatory and reputational risk.

This policy is designed to provide direction to staff on the approach and management of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) within Agaminn. This policy supports management’s objective of mitigating the following risks:

• Money laundering;

• Terrorist financing;

• Sanctions;

• Politically exposed persons (PEPs);

• Legal and regulatory risk.

This policy applies to all individuals working at all levels of Agaminn, including senior managers, officers, directors, employees, consultants, contractors, trainees, homeworkers, part-time and fixed-term workers, casual and agency staff, all of whom are collectively referred to as ‘staff’ in this document.

Senior management of Agaminn will provide direction to, and oversight of, the AML and CTF strategy as well as apply a risk-based approach across the business.

Agaminn has put in place Know-Your-Customer (KYC) programs as an essential element for service, risk management and control procedures.

Such programs include:

• Customer Registration/Acceptance;

• Customer Identification/Verification;

• On-going Monitoring of customers’ activity;

• Risk Management;

• Reporting of suspicious activities to respective authorities.

Agaminn is obliged not only to establish the identity of its customers, but also to monitor account activity to determine those transactions that do not conform with the normal or expected transactions for that customer or type of account. KYC constitutes a core feature of services’ risk management and control procedures. The intensity of KYC programs beyond these essential elements is tailored to the degree of risk.

All Agaminn clients will acknowledge, undertake and agree to the following terms regarding their use of the website, entering into trading activities with Agaminn as a Agaminn client:

1. The client will comply (throughout the time as a Agaminn client) with all relevant statutes pertaining to money laundering and proceeds from criminal activities;

2. Agaminn will operate under certain obligations known as “know-your-customer” obligations which grant Agaminn the right to implement anti money laundering procedures to help detect and prevent money laundering activities where money laundering may mean to handle any funds associated with any illegal activity regardless of the location of such activity;

3. The client agrees to lend full cooperation to Agaminn with respect to anti money laundering efforts. This involves providing information that Agaminn requests regarding account, website usage etc. to help Agaminn perform its duties as dictated by applicable laws, regardless of jurisdiction;

4. Agaminn reserves the right to delay or stop any funds transfer if there is reason to believe that completing such a transaction may result in the violation of any applicable law or is contrary to acceptable practices;

5. Agaminn reserves the right to suspend or terminate any trading activity if there is reason to believe that services are used for activities that are deemed unlawful or fraudulent;

6. Agaminn has the right to use client information for the investigation and/or prevention of fraudulent or otherwise illegal activities;

7. Agaminn has the right to share client information with:

    • Investigative agencies or any authorized officers who are helping Agaminn to comply with applicable law, including anti-money laundering laws and know-your-customer obligations;

    • Organizations that help Agaminn provide the services it offers to its clients;

    • Government, law enforcement agencies and courts;

    • Regulatory bodies and financial institutions.

SUSPICIOUS ACTIVITY REPORTING

When any member of staff either knows, suspects or has reasonable grounds for knowing or suspecting that a money laundering offence has been or is being committed they must make a suspicious activity report.

Staff are not required to actively search for indications that money laundering offences are occurring. However if they become aware of, or suspect that, such offences are occurring during the course of their normal duties then they shall make a SAR.