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

Unifina is committed to preventing money laundering, terrorist financing, fraud, and other financial crimes. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines the measures and procedures implemented by Unifina to ensure compliance with applicable laws and regulatory standards.

1. Purpose

The purpose of this policy is to establish a framework for identifying, assessing, and mitigating risks associated with financial crime. Unifina maintains procedures designed to detect and prevent the use of its platform for money laundering, terrorist financing, and other illicit activities.

2. Regulatory Compliance

Unifina complies with applicable Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) regulations and standards. The company maintains internal controls and procedures to ensure ongoing compliance with relevant legal and regulatory requirements.

3. Know Your Customer (KYC)

To verify the identity of users and reduce the risk of fraud or financial crime, Unifina implements a robust KYC process.

User identity verification is conducted through QoreID, a digital identity verification platform and a subsidiary of VerifyMe. QoreID enables Unifina to securely verify user identities using trusted government and financial databases.

The verification process may include:

• Verification of government-issued identification
• Validation of personal information such as name, date of birth, and address
• Biometric verification where applicable
• Phone number or email verification
• Cross-checks against trusted identity databases

Unifina may request additional information or documentation where necessary to complete verification or to comply with regulatory obligations.

4. Customer Due Diligence

Unifina performs Customer Due Diligence (CDD) when users create accounts and when certain financial activities occur on the platform. The level of due diligence applied may vary depending on the risk profile of the user.

In higher-risk situations, Unifina may apply Enhanced Due Diligence (EDD), which may include additional identity verification, monitoring of account activity, or requests for additional documentation.

5. Transaction Monitoring

Unifina monitors transactions conducted on its platform to identify potentially suspicious activities. Automated systems and internal review procedures are used to detect unusual patterns, high-risk behavior, or transactions that may indicate financial crime.

Examples of monitored activities include:

• Unusual transaction patterns
• Transactions involving high-risk jurisdictions
• Rapid movement of funds without clear economic purpose
• Multiple accounts associated with the same identity

Where necessary, accounts or transactions may be temporarily restricted while further review is conducted.

6. Sanctions Screening

Unifina maintains procedures to screen users and transactions against applicable sanctions lists and watchlists to ensure compliance with international financial regulations.

If a user or transaction matches a sanctioned individual, organization, or jurisdiction, Unifina may block or suspend the account and take further action as required by law.

7. Reporting of Suspicious Activity

If suspicious activity is identified, Unifina may investigate the activity and take appropriate action, which may include restricting accounts, refusing transactions, or reporting the activity to relevant regulatory or law enforcement authorities where required.

8. Record Keeping

Unifina maintains records of identity verification, transaction activity, and compliance reviews for the period required under applicable laws and regulatory standards. These records are securely stored and protected against unauthorized access.

9. Ongoing Monitoring

User accounts and transactions may be subject to ongoing monitoring throughout the relationship with Unifina. The company periodically reviews its AML and KYC procedures to ensure they remain effective and aligned with regulatory requirements.

10. Policy Updates

Unifina may update this AML and KYC Policy from time to time to reflect changes in regulatory obligations, technology, or operational practices. Updated versions will be made available through the Unifina platform or website.