RULES
of Anti-Money Laundering and Combating The Financing Terrorism Compliance

Control

1. General Provisions

1.1. These rules establish the principles and procedures for preventing money laundering (AML) and combating the financing of terrorism (CFT) within the Stash Tech solutions Limited, incorporated under the laws of the Republic of Seychelles, having its registered address at House of Francis, Room 303, ile Du Port, Mahe, Seychelles (hereinafter referred to as the “Company”).

1.2. The Company operates in the field of software development and modification, backup services, and IT consulting and adheres to international AML/CFT regulations.

1.3. The Company implements preventive measures to mitigate risks associated with AML/CFT violations.

2. Definitions

For the purposes of these Rules, the following terms shall have the meanings assigned to them:

• Anti-Money Laundering (AML): Measures and processes aimed at preventing the use of financial systems and business operations for laundering illegally obtained funds.

• Combating the Financing of Terrorism (CFT): Actions taken to prevent, detect, and report financial activities that support terrorist organizations.

• Know Your Customer (KYC): The process of verifying the identity of clients (individuals) before establishing a business relationship, including identity documentation and risk assessment.

• Know Your Business (KYB): The process of verifying the identity and legitimacy of corporate clients and business partners, including registration documents, ownership structures, and financial activities.

• Risk-Based Approach: A methodology for assessing and managing AML/CFT risks based on the likelihood and impact of potential threats.

• Sanctions List: A list of individuals, companies, or entities subject to restrictions imposed by governments or international organizations due to AML/CFT concerns.

• Suspicious Activity: Any transaction, business relationship, or financial behavior that may indicate money laundering, fraud, or terrorist financing.

3. Risk-Based Approach

3.1. The Company applies a risk-based approach to identify, assess, and manage risks related to AML/CFT.

3.2. Key risk factors include:

• Engagement with high-risk clients or jurisdictions;

• Potential misuse of IT services for illicit financial activities;

• Involvement in transactions that lack transparency.

3.3. The Company periodically reviews and updates its risk assessment policies.

4. KYC and KYB Procedures

4.1. The Company applies KYC and KYB procedures for business partners and clients,

including:

• Verification of individuals (KYC) through identity documents, where applicable;

• Verification of companies (KYB) by reviewing registration documents, business licenses, and ownership structure;

• Screening against sanctions lists and AML/CFT watchlists;

• Identifying the nature and legitimacy of the business relationship.

4.2. If suspicious activity is detected or if a client/business partner fails to provide necessary verification, the Company reserves the right to request additional information or terminate cooperation.

4.3. The Company may cross-check the customer through appropriate sanctions lists including but not limited to:

• OFAC SDN;

• United Nations Security Council Sanctions List;

• World Bank - Ineligible Firms And Individuals List;

• EU - Financial Sanctions List;

• UK - HMT Financial Sanctions List;

• AU - DFAT Consolidated Sanction List;

• US - Bureau Of Industry And Security List;

• CH - SECO Sanction List;

• US - Department Of State Nonproliferation Sanctions List;

• Interpol Wanted List.

5. Monitoring and Reporting

5.1. The Company monitors its business activities and client engagements to detect potential AML/CFT violations.

5.2. If suspicious activity is identified, the Company will:

• Conduct an internal review and gather relevant details;

• Report the case to the designated compliance officer;

• Notify authorities if required by law.

5.3. Employees and relevant departments are required to report any suspicious activity immediately.

6. Governing law

These Rules shall be governed and construed in accordance with the laws of the Republic of Seychelles, without regard to its conflict of law provisions.

7. Cooperation with Authorities

7.1. The Company complies with law enforcement requests related to AML/CFT investigations.

7.2. If required, the Company provides relevant documentation and information in accordance with applicable legal frameworks.

8. Final Provisions

8.1. These rules are reviewed and updated regularly to reflect changes in AML/CFT regulations.

8.2. Failure to comply with these rules may result in termination of business relationships.