Anti-Money Laundering (AML) Policy

1. Introduction

LLC "Blob Solutions" (hereinafter referred to as the "Company") is committed to preventing the use of its platform and services for money laundering, terrorist financing, and other illicit activities. This Anti-Money Laundering (AML) Policy outlines the Company's measures to ensure compliance with applicable laws and regulations in the Republic of Armenia and internationally.

The Company adopts this AML Policy to ensure transparency, protect the integrity of the financial system, and safeguard its reputation. The AML Policy applies to all employees, agents, and contractors of the Company, as well as to all users and clients engaging with the Company's services.

2. Scope

This AML Policy applies to all services provided by the Company, including but not limited to the issuance and management of redeemable instruments, handling transactions on the platform, and all activities involving the transfer of funds. It covers the following key areas:

• Customer Due Diligence (CDD)
• Ongoing Monitoring
• Record Keeping
• Reporting Obligations
• Training and Awareness

3. Legal Framework

The Company adheres to the AML requirements set forth in the following legal and regulatory frameworks:

• The Law of the Republic of Armenia on Anti-Money Laundering and Countering the Financing of Terrorism.
• Relevant international standards and guidelines, including those established by the Financial Action Task Force (FATF).
• Any additional AML regulations applicable in the jurisdictions where the Company operates.

4. Customer Due Diligence (CDD)

4.1. Identification and Verification

The Company requires all clients and users to undergo a robust identification and verification process before gaining access to the platform's services. The following steps shall be taken:

• Identification: Collection of personal information, including but not limited to full legal name, date of birth, nationality, residential address, and contact details.
• Verification: Verification of the provided information through reliable and independent sources, such as government-issued identification documents (e.g., passport, national ID, driver's license) and utility bills.

4.2. Risk-Based Approach

The Company adopts a risk-based approach to CDD, categorizing clients into different risk levels (low, medium, high) based on factors such as the nature of their business, geographic location, and transaction history. Enhanced due diligence (EDD) measures are applied to clients classified as high risk, including:

• Obtaining additional information on the client and the purpose of their transactions.
• Requiring senior management approval for establishing or continuing business relationships with high-risk clients.
• Ongoing monitoring of high-risk clients’ transactions.

4.3. Beneficial Ownership

The Company requires identification and verification of the ultimate beneficial owners (UBOs) of corporate clients and legal entities. The UBO is defined as any individual who ultimately owns or controls 25% or more of the entity.

4.4. Politically Exposed Persons (PEPs)

The Company applies enhanced scrutiny to relationships involving Politically Exposed Persons (PEPs) due to their increased risk of involvement in corruption and bribery. PEPs include individuals who are or have been entrusted with prominent public functions, as well as their immediate family members and close associates.

5. Ongoing Monitoring

5.1. Transaction Monitoring

The Company monitors all transactions conducted on its platform for suspicious activities that may indicate money laundering or terrorist financing. This includes:

• Monitoring for unusual transaction patterns, such as large or complex transactions, rapid movements of funds, and transactions with high-risk jurisdictions.
• Cross-checking transactions against known lists of sanctioned individuals and entities.

5.2. Suspicious Activity Reporting (SAR)

Employees are required to report any suspicious activity to the Company's designated AML Compliance Officer. The Company will investigate and, if necessary, file a Suspicious Activity Report (SAR) with the appropriate authorities in accordance with legal requirements.

6. Record Keeping

The Company maintains detailed records of all CDD information, transactions, and reports for a minimum of five years, in compliance with legal requirements. Records include:

• Client identification documents.
• Records of all transactions conducted on the platform.
• Documentation of the risk assessments and due diligence procedures.
• Copies of SARs and any related correspondence with regulatory authorities.

These records must be securely stored and accessible to authorized personnel only.

7. Reporting Obligations

The Company is committed to fulfilling all reporting obligations under applicable AML laws and regulations, including:

• Filing SARs with the Financial Monitoring Center of the Republic of Armenia or other relevant authorities when there is a suspicion of money laundering or terrorist financing.
• Reporting large cash transactions and any other reportable transactions as required by law.
• Cooperating fully with law enforcement and regulatory authorities during investigations.

8. Training and Awareness

8.1. Employee Training

All employees, agents, and contractors of the Company receive regular AML training to ensure they are aware of their responsibilities under this policy. Training covers:

• The legal and regulatory framework of AML.
• Identification of suspicious activities and red flags.
• Proper procedures for reporting suspicious activities.
• Updates on emerging AML threats and regulatory changes.

8.2. Ongoing Education

The Company provides ongoing education and resources to ensure that all staff remain informed about the latest developments in AML practices and regulations. This includes regular updates and refresher training sessions.

9. Compliance and Internal Audit

9.1. AML Compliance Officer

The Company appoints a dedicated AML Compliance Officer responsible for overseeing the implementation of this AML Policy, ensuring compliance with all AML obligations, and serving as the primary point of contact for regulatory authorities.

9.2. Internal Audit

The Company's internal audit function regularly reviews the effectiveness of the AML Policy and the implementation of its procedures. The audit includes:

• Assessing the adequacy and effectiveness of CDD processes.
• Reviewing transaction monitoring systems and procedures.
• Ensuring that record-keeping and reporting obligations are being met.

The findings of the audit are reported to senior management, and corrective actions are taken as necessary.

10. Sanctions Compliance

The Company strictly adheres to all applicable international, national, and local sanctions regimes. The Company maintains up-to-date sanctions lists and ensures that no transactions are conducted with sanctioned individuals, entities, or countries. The sanctions compliance program includes:

• Regular screening of clients and transactions against sanctions lists.
• Immediate suspension of any activity involving a sanctioned party.
• Reporting of sanctions-related violations to the relevant authorities.

11. Data Protection

The Company ensures that all personal data collected and processed under this AML Policy complies with data protection laws, including the General Data Protection Regulation (GDPR) where applicable. The Company commits to:

• Protecting the privacy and security of client data.
• Ensuring that data is only used for legitimate AML purposes.
• Providing clients with the right to access, correct, and delete their personal data in accordance with legal requirements.

12. Amendments and Updates

This AML Policy is subject to regular review and may be amended or updated by the Company to reflect changes in legal, regulatory, or operational requirements. All amendments will be communicated to employees, agents, and clients, and will take effect upon publication on the Company's platform.

13. Conclusion

The Company is committed to maintaining the highest standards of integrity and transparency in its operations. This AML Policy represents a key component of the Company's broader compliance framework and reflects its dedication to preventing money laundering, terrorist financing, and other illicit activities.

Date of Issue: 21.08.2024

Version: 1.0

Approved by: Alexander Kraiz, Director of LLC "Blob Solutions"