AML & KYC Policy

TradingBase Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Document ID: LEG-011Version: 1.0Status: Draft for Legal ReviewEffective Date: [To be inserted]Last Updated: [To be inserted]

• Purpose

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy (“Policy”) establishes the principles adopted by TradingBase to prevent the misuse of its Platform for money laundering, terrorist financing, fraud, sanctions evasion, or other unlawful financial activities.

This Policy supplements the TradingBase Terms of Service and other applicable legal documents.

Nothing in this Policy should be interpreted as a representation that TradingBase is a regulated financial institution unless expressly stated under applicable law.

• Scope

This Policy may apply to:

subscription payments;

Marketplace transactions;

partner programs;

affiliate programs;

vendor onboarding;

enterprise customers;

digital asset services (where available);

wallet services (where available);

reward or incentive programs involving monetary value.

Certain Platform features may not require identity verification.

• Risk-Based Approach

TradingBase applies a risk-based approach to customer due diligence.

Verification requirements may vary depending on factors including:

account activity;

transaction volume;

geographic location;

product type;

payment method;

applicable legal obligations.

Enhanced review may be applied where higher risks are identified.

• Customer Identification

Where identity verification is required, TradingBase may request information such as:

legal name;

date of birth;

residential address;

government-issued identification;

proof of address;

company registration documents (for legal entities);

beneficial ownership information where applicable.

The scope of verification may vary according to applicable law.

• Verification Procedures

Verification may include:

document validation;

biometric verification where supported;

database checks;

sanctions screening;

politically exposed person (PEP) screening where appropriate;

fraud detection measures.

TradingBase may engage qualified third-party verification providers.

• Ongoing Monitoring

Where required, TradingBase may monitor account activity to identify unusual or suspicious behavior.

Monitoring may include:

transaction patterns;

account access anomalies;

unusual payment activity;

multiple account creation;

rapid changes in account information;

indicators of fraud or abuse.

Monitoring is conducted in accordance with applicable law.

• Sanctions Compliance

TradingBase may restrict access where required to comply with applicable sanctions laws or governmental restrictions.

TradingBase may decline or terminate services involving persons, entities, or jurisdictions subject to applicable legal restrictions.

• Suspicious Activity

TradingBase reserves the right to investigate activity that reasonably appears to involve:

fraud;

identity theft;

money laundering;

terrorist financing;

sanctions violations;

stolen payment methods;

account takeover;

other unlawful conduct.

Where legally required, TradingBase may report relevant information to competent authorities.

• Record Retention

Where required by law, TradingBase may retain records relating to:

identity verification;

transaction history;

compliance reviews;

investigations;

communications relevant to regulatory obligations.

Retention periods are determined in accordance with applicable legal requirements and the Privacy Policy.

• User Responsibilities

Users subject to identity verification are responsible for:

providing accurate information;

updating information when changes occur;

cooperating with reasonable verification requests;

refraining from using false or misleading documents.

Providing false information may result in account suspension or termination.

• Refusal of Service

TradingBase may refuse or discontinue services where:

required verification cannot be completed;

fraudulent documentation is suspected;

legal obligations prohibit continued service;

unacceptable compliance risks are identified.

Such decisions are made in accordance with applicable law.

• Privacy and Confidentiality

Information collected under this Policy is handled in accordance with the TradingBase Privacy Policy.

Access to verification information is restricted to authorized personnel and service providers with a legitimate business or legal need.

• Third-Party Service Providers

TradingBase may engage third-party providers to assist with:

identity verification;

sanctions screening;

fraud prevention;

compliance monitoring;

document authentication.

Such providers are expected to maintain appropriate security and confidentiality standards.

• International Compliance

TradingBase operates in multiple jurisdictions.

Compliance procedures may vary depending on applicable legal requirements in the relevant jurisdiction.

Nothing in this Policy limits obligations imposed by mandatory local laws.

• Policy Updates

TradingBase may revise this Policy to reflect:

legal developments;

regulatory requirements;

operational improvements;

evolving financial crime risks.

Updated versions become effective on the date specified in the revised Policy.

• Contact

Questions regarding this AML & KYC Policy should be submitted through TradingBase’s official compliance support channels.

Appendix A — Examples of Verification Documents

Illustrative examples include:

passport;

national identity card;

driver’s license;

residence permit;

utility bill;

bank statement;

company registration certificate;

proof of beneficial ownership.

Acceptance of specific documents depends on jurisdiction and applicable legal requirements.

Appendix B — Examples of High-Risk Indicators

Examples of activity that may require additional review include:

Risk Indicator

Example

Multiple Accounts

Creation of numerous related accounts

Identity Concerns

Inconsistent identity information

Payment Irregularities

Repeated failed or disputed transactions

Geographic Risk

Activity involving higher-risk jurisdictions

Unusual Behaviour

Significant changes inconsistent with historical usage

These examples are illustrative and do not automatically indicate unlawful activity.

Appendix C — User Cooperation

Users may be asked to:

confirm identity;

explain transaction activity;

provide supporting documentation;

respond to compliance inquiries within a reasonable period.

Failure to cooperate may affect continued access to services requiring verification.

Nothing in this Policy limits any rights or protections available to users under applicable law.