AML Policy

At Alfred, we are resolute in our commitment to combat money laundering, terrorism financing, and associated illicit activities. This AML Policy underscores our dedication to maintaining transparency and integrity in all trading operations while adhering to relevant laws and regulations.

1.1 Throughout this policy, "We," "Our," "Company," "Alfred," and "Us" refer to Alfred Analytics FZCO, while "User," "You," and "Your" pertain to individuals using our Online Platforms.

1.2 In this AML Policy:

1. a. “Beneficial Owner” means: (i)In the case of companies, the natural person who has ownership of over 25% (twenty-five percent) of the shares, is entitled to over 25% (twenty-five percent) of the profits, or has the power, directly or indirectly, to appoint or elect more than half of the board of directors of such company, as the case may be (ii)In the case of partnership firms/Limited Liability Partnerships, the natural person who has ownership of over 15% (fifteen percent) of the capital or is entitled to over 15% (fifteen percent) of the profits of such firm, as the case may be

2. b. “Sanction Lists” refer to lists of natural and juridical persons included under any list circulated by any country or government or international authority, including the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the US Department of State, the United Nations Security Council, the European Union, Her Majesty’s Treasury, the Hong Kong Monetary Authority or the Monetary Authority of UAE and relevant applicable laws.

3. c. “Suspicious Transactions” refers to the following activities, whether attempted or executed: (i) Terrorist Financing: shall mean any transactions which to a person acting in good faith appear to be any funds collected to be used, in full or in part, by any terrorist or related organization, or in order to carry out any of the activities relating to terrorism, or terrorist acts, including all “Terrorism Financing Offence” as defined in the Terrorism (Suppression of Financing) Act (ii) Unusually Complex: transactions which to a person acting in good faith appear to have been structured in a manner of unusual or unjustified complexity or (iii) Malafide Purpose: transactions that to a person acting in good faith appear to have not been transacted for a bonafide purpose or have a sound economic rationale.

1.3 The capitalized terms used herein, but not defined, shall have the meaning given to such terms in the Terms (defined below).

2. AML is Part of Our Terms

2.1 This AML Policy is an integral part of and incorporated within the User Terms and Conditions.

3. Policy Changes

3.1 The Company may change and update this AML Policy from time to time. It is advisable for users to review the policy regularly.

4. Your Obligations

4.1 Users acknowledge their duty to comply with the terms and conditions outlined in this AML Policy.

4.2 Users must ensure that any personal information submitted belongs to them.

4.3 Users are required to file a fresh proof of address within six months of changing their address.

4.4 Users acting on behalf of a juridical person must identify the Beneficial Owner and assist in verifying their identity.

5. Purpose of This Policy

5.1 The policy's purpose is to mitigate risks related to money laundering and other illegal activities through Customer Acceptance Terms and Risk Management Procedure.

• Customer Acceptance Terms

• Risk Management Procedure

6. Customer Acceptance Terms

6.1 The Company may either at the time of onboarding, or while undertaking any transactions, during Periodic Updates, or for any other reason, ensure your compliance with the following:

1. Require you to submit such additional information and/or data as may be directed by a competent enforcement authority.

6.2 The Company may, in its sole discretion, refuse to onboard new wallets, terminate the access to the platform's existing user wallets after giving due notice, or refuse to process any transactions on the Online Platforms if it is unable to ensure compliance with any of the aforementioned conditions, either due to non - cooperation by the User.

7. Transaction Monitoring and Details Sharing

7.1 All transactions are publicly available on the blockchain, and transaction details may be shared with regulatory or law enforcement authorities.

7.2 Under the anti-money laundering practices alfred is open to share all the available transactions details with regulatory authorities when called to do so.

7.3 The Company reserves the right to take actions, including blacklisting, restricting access, or reporting to authorities, for suspicious transactions.

8. Compliance, Disclosure And Notices

8.1 The Company may share, from time to time, information regarding transactions identified under Clause 7 (Transaction Monitoring and Details Sharing), identification information of such Users, or any other information mandated under the applicable law, with the appropriate enforcement authorities.

8.2 In order to improve the integrity and transparency of transactions on Alfred, you are encouraged to report any information you are privy to or become privy to in the future regarding any Suspicious Transactions or transactions you have find or have reason to believe are dubious in nature, to our Compliance Officers by writing to them at [email protected].

8.3 In order to ensure compliance with this AML Policy and/or the applicable laws, the Company may be required to send you notices from time to time. Where you are required to share any information according to the procedures contained in this AML Policy, such communication may be made by you electronically by sending an email at [email protected]

8.4 You may also contact us at the following: Contact number: [phone] Email: [email protected] Mailing Address: DSO-IFZA, IFZA Properties, Dubai Silicon Oasis, Dubai, United Arab Emirates