This Anti-Money Laundering (AML ) Policy outlines the measures and procedures implemented by Midaz  ("we," "us," or "our") to prevent money laundering and terrorist financing activities through our services. We are committed to complying with all applicable AML laws and regulations.

1. What is Money Laundering?

Money laundering is the process of concealing the origins of illegally obtained money, typically by means of transfers involving foreign banks or legitimate businesses. It involves three stages:

• Placement: Introducing illicit funds into the financial system.

• Layering: Conducting complex transactions to obscure the audit trail and disguise the source of funds.

• Integration: Returning the money to the criminal from what appear to be legitimate sources.

2. Our Commitment

Midaz  is dedicated to maintaining the highest standards of AML compliance. Our policy includes:

• Risk-Based Approach: Assessing and managing AML risks based on customer type, geographic location, products, services, and delivery channels.

• Customer Due Diligence (CDD): Implementing robust procedures to verify the identity of our clients.

• Monitoring: Continuously monitoring transactions and account activity for suspicious patterns.

• Reporting: Reporting suspicious activities to the relevant authorities.

• Record Keeping: Maintaining records of all transactions and customer identification data.

• Training: Providing ongoing AML training to our employees.

3. Customer Due Diligence (CDD) / Know Your Customer (KYC)

As part of our CDD process, we require all clients to provide reliable, independent source documents to verify their identity. This typically includes:

• Proof of Identity: A valid government-issued identification document (e.g., passport, national ID card, driver's license) with a clear photo, full name, date of birth, and expiration date.

• Proof of Address: A recent utility bill (electricity, water, gas, internet) or bank statement (issued within the last 3-6 months) showing your full name and residential address.

• Source of Funds/Wealth: In certain cases, we may request documentation to verify the source of funds or wealth used for transactions.

We reserve the right to request additional documentation at any time to comply with our AML obligations. Failure to provide requested documentation may result in account suspension or termination.

4. Transaction Monitoring

We employ automated and manual systems to monitor client transactions for unusual or suspicious patterns. This includes:

• Monitoring deposit and withdrawal patterns.

• Analyzing transaction volumes and frequencies.

• Identifying transactions with high-risk jurisdictions.

• Detecting unusual account activity inconsistent with the client's profile.

5. Reporting Suspicious Activities

Any suspicious activity identified will be investigated by our compliance team. If reasonable suspicion of money laundering or terrorist financing exists, we will report such activities to the appropriate financial intelligence unit (FIU) or regulatory authority, as required by law.

6. Record Keeping

We maintain records of all customer identification data, transaction records, and any reports of suspicious activity for a minimum period as required by applicable laws and regulations.

7. Training

All relevant employees receive regular training on AML policies and procedures, enabling them to recognize and report suspicious activities.

8. Sanctions Policy

Midaz  adheres to international sanctions lists (e.g., OFAC, UN, EU). We screen clients and transactions against these lists to prevent engagement with sanctioned individuals or entities.

9. Contact Us

If you have any questions about our AML Policy, please contact our compliance department at [email protected]