Anti-Money Laundering (AML) Policy

Last Updated: March 26, 2025

1. Introduction

Qtech Middle East Ltd ("the Company," "we," "us," or "our") is committed to the highest standards of Anti-Money Laundering (AML) compliance and requires its management, employees, and clients to adhere to these standards to prevent the use of our services for money laundering or terrorist financing purposes. This policy has been designed in accordance with international standards, including FATF Recommendations and relevant regulatory requirements applicable to cryptocurrency CFD trading platforms.

2. Definitions

For the purpose of this policy:

• Money Laundering: The process of converting funds derived from illegal activities into funds that appear to be legitimate.
• Terrorist Financing: The provision, collection, or movement of funds intended for terrorist activities.
• Politically Exposed Person (PEP): An individual who is or has been entrusted with a prominent public function, including their family members and close associates.
• Suspicious Transaction: Any transaction that appears unusual, lacks economic justification, may be connected to an unlawful activity, or deviates from the customer's normal transactional patterns.

3. Risk-Based Approach

The Company applies a risk-based approach to AML/CTF compliance, which includes:

1. Assessing the money laundering and terrorist financing risks associated with our clients, products, delivery channels, and geographical locations
2. Implementing appropriate customer due diligence measures proportionate to the identified risks
3. Ongoing monitoring of business relationships and transactions
4. Regular review and update of risk assessments

4. Customer Due Diligence (CDD)

The Company conducts appropriate customer due diligence on all clients before establishing a business relationship, which includes:

• Identifying and verifying the client's identity using reliable, independent source documents, data, or information
• Identifying the beneficial owner and taking reasonable measures to verify their identity
• Understanding the purpose and intended nature of the business relationship
• Conducting ongoing due diligence on the business relationship and scrutiny of transactions

Enhanced due diligence measures will be applied to:

• High-risk clients, including Politically Exposed Persons (PEPs)
• Business relationships and transactions with individuals from high-risk countries
• Complex, unusual large transactions, or unusual patterns of transactions that have no apparent economic or lawful purpose

5. Transaction Monitoring

The Company maintains a comprehensive transaction monitoring system designed to:

• Identify suspicious or unusual transactions
• Match client activity against known typologies and red flags
• Monitor transactions against clients' established patterns of activity
• Screen transactions against sanctions and PEP lists
• Generate alerts for further investigation by the AML Compliance Team

6. Record Keeping

The Company maintains all records relating to customer identity and transactions for a minimum of five years after the termination of the business relationship or completion of the transaction. These records include:

• Identity verification documents
• Transaction records
• Business correspondence
• Results of any analysis undertaken
• Reports of suspicious transactions

7. Suspicious Transaction Reporting

The Company has established internal procedures for the reporting of suspicious transactions, which include:

• Employee obligation to report suspicious activities to the AML Compliance Officer
• Review of suspicious transaction reports by the AML Compliance Officer
• Filing of suspicious transaction reports with the relevant Financial Intelligence Unit or other regulatory authorities as required by law
• Prohibition of "tipping off" clients about reports or investigations

8. Training and Awareness

The Company provides regular training to all relevant employees on:

• AML/CTF laws, regulations, and standards
• Money laundering and terrorist financing typologies and red flags
• Internal AML/CTF policies, procedures, and controls
• Customer due diligence requirements
• Record keeping requirements
• Suspicious transaction reporting procedures

9. Compliance Program

The Company has established a comprehensive AML compliance program that includes:

• Appointment of an AML Compliance Officer with sufficient authority, resources, and independence
• Development and implementation of internal policies, procedures, and controls
• Ongoing employee training program
• Independent audit function to test the effectiveness of the compliance program
• Regular review and update of the compliance program to reflect changes in regulations, business activities, or risk assessment

10. Cooperation with Regulatory Authorities

The Company is committed to cooperating with relevant regulatory and law enforcement authorities, including:

• Responding promptly to inquiries and information requests
• Providing complete and accurate information as required
• Implementing any regulatory guidance or directives
• Ensuring that banking and other third-party relationships comply with relevant laws and regulations

11. Sanctions Compliance

The Company adheres to all applicable sanctions regimes and will not engage in business with:

• Individuals, entities, or countries that are subject to international sanctions
• Entities owned or controlled by sanctioned parties
• Entities acting on behalf of sanctioned parties

12. Policy Review and Updates

This AML Policy will be reviewed at least annually or more frequently if necessary, to reflect:

• Changes in applicable laws, regulations, or industry standards
• Changes in the Company's business activities or risk profile
• Findings from internal or external audits or regulatory examinations
• Lessons learned from actual cases or industry developments

This policy is effective as of March 26, 2025, and supersedes any previous versions.