AML/ATF
Compliance Statement

About this statement. This statement summarises UNYX AI CA LTD's AML/ATF compliance programme
for clients, counterparties and the public. It is updated whenever the programme changes materially.

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1. About UNYX
UNYX AI CA LTD (UNYX) is incorporated in Ontario, Canada (Ontario Corporation No. 1001253500). It is
registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a money
services business (registration no. C10001322) for foreign exchange dealing, money transferring and
dealing in virtual currency, and with the Bank of Canada as a payment service provider under the Retail
Payment Activities Act (Entity ID RPS0015158). UNYX is a wholly owned subsidiary of UNYX AI LTD
(United Kingdom), which provides its technology platform.

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UNYX provides multi-currency accounts, cross-border payments, foreign exchange and digital asset wallets and transfers to entity clients, principally regulated financial institutions and corporate entities.

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Member institutions may also make accounts and wallets on the UNYX platform available to their own customers.

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2. Our Commitment
UNYX does not tolerate money laundering, terrorist financing, proliferation financing, sanctions evasion or fraud. We comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations, Canadian sanctions law and FINTRAC guidance, and we apply the recommendations of the Financial Action Task Force (FATF). Our compliance programme covers every product, service, client, end
customer, currency and corridor on our platform, and no product, service or corridor is launched without
compliance review and approval.

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3. Governance
• Our AML/ATF Policy and our business-wide risk assessment are approved by our Board of Directors, which is ultimately accountable for the programme.
• We have appointed a compliance officer, who is our Money Laundering Reporting Officer. The
compliance officer is independent of commercial functions, reports directly to the Chief Executive Officer and, where necessary, to the Board, and has the authority to block transactions and suspend relationships.

• Written procedures set out how each part of the programme operates. The Policy is reviewed at
least annually, and the programme is independently reviewed at least every two years.

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4. Risk-Based Approach
We assess the money laundering, terrorist financing, proliferation financing and sanctions risks of our business, and we risk-rate every client. The level of due diligence, monitoring and approval we apply is proportionate to that risk. Enhanced due diligence applies to higher-risk relationships, including those involving politically exposed persons, high-risk jurisdictions, complex ownership structures or significant virtual asset exposure, and higher-risk relationships require senior approval.

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5. Knowing Our Clients
• We onboard entity clients only. We do not onboard individuals as direct clients.
• For every client we verify its existence and status, identify and verify its beneficial owners through every layer of ownership, identify its directors and authorised persons, and verify any licence or registration against the regulator's public register.
• We establish the purpose and intended nature of the relationship and the expected activity, and, where required, the source of funds and source of wealth.
• No account or wallet is activated until due diligence is complete and a risk rating has been assigned. Due diligence is refreshed periodically according to risk, and whenever a client's circumstances change.
• We do not open anonymous or fictitious accounts, and we do not deal with shell banks.

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6. End Customers of Member Institutions
Where a member institution makes accounts or wallets available to its own customers, UNYX is responsible for identifying each of those end customers. The member carries out the identification on UNYX's behalf under a written agreement, and sends UNYX the identification information together with the underlying verification records. UNYX reviews every file, screens, risk-rates and monitors every end customer, and records each one individually on its ledger, including where balances are held in a pooled account. No end customer is activated until the agreement is in force and UNYX has reviewed the records.
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An end customer may not onboard its own customers or open further sub-accounts. A financial institution that wishes to serve its own customers must be onboarded by UNYX as a direct client.

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7. Sanctions and Screening
We comply with sanctions imposed by Canada, including under the Special Economic Measures Act, the Justice for Victims of Corrupt Foreign Officials Act, the United Nations Act and the Criminal Code, and we also screen against the sanctions lists of the United Nations, the United States, the European Union and the United Kingdom. We screen clients, beneficial owners, directors, end customers, counterparties and wallet addresses at onboarding, on an ongoing basis and at transaction level, and we screen for politically exposed persons and adverse media. Where required, we freeze property and make the disclosures and reports the law requires.

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8. Prohibited Jurisdictions and Activities
• We do not deal with jurisdictions subject to comprehensive sanctions, jurisdictions subject to an FATF call for action, or other jurisdictions we designate as prohibited, including the occupied regions of Ukraine. Relationships and transactions connected with higher-risk jurisdictions, including those under FATF increased monitoring, are subject to enhanced due diligence and monitoring.
• We do not provide services for activities that are unlawful, that involve sanctioned persons or sanctions evasion, that are regulated but carried on without the licence they require in any jurisdiction where the client serves customers, or that fall outside our risk appetite.
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9. Monitoring
We monitor fiat and virtual asset transactions using automated rules that are reviewed and calibrated regularly, and we use blockchain analytics to identify exposure to sanctioned addresses, mixers, darknet markets, scams and other illicit sources. Transfers involving wallets that are not held by a regulated provider are subject to additional controls, including confirmation of wallet ownership. Alerts are reviewed by our compliance function, and suspicious activity is escalated to the compliance officer.
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10. Travel Rule
For every electronic funds transfer and every virtual currency transfer of CAD 1,000 or more, or its equivalent, we send and receive the originator and beneficiary information the law requires. Outbound transfers with incomplete information are not released, and inbound transfers that arrive without it are held while the information is obtained.

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11. Reporting and Confidentiality
We file suspicious transaction reports, electronic funds transfer reports, large virtual currency transaction reports, terrorist property reports and any reports required under a Ministerial Directive with FINTRAC, and we make the reports required by the Bank of Canada under the Retail Payment Activities Act. Reporting is confidential: we do not inform clients or anyone else that a report has been made or that an investigation exists.
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12. Record Keeping
We keep identification, beneficial ownership, transaction, screening, monitoring and reporting records for seven years, exceeding the five-year minimum required by law, from the date a record is created or from the end of the business relationship, whichever is later. Records are held securely, with access restricted, and can be provided to FINTRAC within thirty days of a request.

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13. Training
All employees, officers, directors and contractors receive AML/ATF training when they join and every year after that, and complete an assessment. Training is also given whenever a regulatory or programme change affects how people must act.

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14. Working With Financial Institutions
We carry out due diligence on the financial institutions and counterparties we work with, including their licences and their AML/ATF programmes, and we welcome their due diligence on us. Our due diligence documentation is available to regulated counterparties on request.
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15. Contact
For compliance enquiries, or to report a concern about financial crime, contact compliance@unyx.ai.