KYC & AML Policy

1. Our Commitment

FinZuro (“FinZuro”, “we”, “us”, or “our”) is committed to maintaining a robust framework designed to prevent our services from being used for money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud, or other forms of financial crime.

We apply a risk-based approach to customer due diligence and financial crime prevention. This means that the level of verification, due diligence and ongoing monitoring applied to a customer may vary depending on the nature and level of risk associated with the customer, their circumstances, and their activity.

Our procedures are designed to support compliance with applicable British Virgin Islands laws and regulations, including applicable anti-money laundering, counter-terrorist financing and counter-proliferation financing requirements, applicable sanctions requirements, regulatory requirements, and recognized international standards.

This policy provides a general overview of our approach to KYC and financial crime prevention. It does not describe all of our internal controls, monitoring methodologies, risk thresholds, investigative procedures, or other confidential compliance processes.

2. Know Your Customer (KYC)

Before providing certain services or allowing a customer to establish or maintain a trading relationship, FinZuro may be required to verify the customer's identity and obtain information necessary to understand the nature and purpose of the relationship.

Depending on the circumstances, we may request:

• Full legal name
• Date and place of birth
• Residential address
• Nationality
• Contact information
• Government-issued identification
• Proof of residential address
• Tax identification information
• Employment or business information
• Source of funds
• Source of wealth
• Information concerning the intended use of the account
• Information concerning investment knowledge and experience, where applicable

We may request additional information or documentation where required by applicable law, our internal risk assessment, or our compliance procedures.

3. Identity Verification

We use appropriate procedures to verify customer identities and, where applicable, may use independent verification and screening providers.

Documents may be subject to authenticity, validity, and consistency checks.

We may also request additional information where:

• Information provided is incomplete or inconsistent
• Documents cannot be adequately verified
• There are concerns regarding the identity of a customer
• The customer's circumstances have changed
• Additional verification is required as part of our risk assessment or ongoing due diligence

Providing false, misleading, or materially incomplete information may result in an application or account being declined, restricted, suspended, or closed.

4. Beneficial Ownership

For corporate, partnership, trust, or other legal-entity customers, FinZuro may identify and verify the individuals who ultimately own, control, or exercise effective control over the customer.

Depending on the circumstances, we may request information concerning:

• The legal entity
• Directors and equivalent officers
• Shareholders
• Beneficial owners
• Persons exercising ultimate control
• Authorized representatives
• The ownership and control structure

We may request updated ownership or control information when circumstances change or when required as part of our ongoing due diligence.

5. Customer Risk Assessment

FinZuro assesses customer relationships using a risk-based approach.

Relevant factors may include:

• Customer type and ownership structure
• Country or geographic exposure
• Source of funds and source of wealth
• Nature and purpose of the relationship
• Products and services used
• Transaction and account activity
• Politically exposed person (PEP) status
• Sanctions exposure
• Adverse information or other relevant risk indicators
• The complexity or unusual nature of the customer's activity

A higher-risk assessment does not necessarily mean that a customer will be refused service. It may, however, result in additional verification, enhanced due diligence, increased monitoring, additional controls, or other appropriate measures.

6. Enhanced Due Diligence

Where a customer or relationship presents increased financial crime risk, FinZuro may apply enhanced due diligence measures.

These measures may include:

• Requesting additional identification or supporting documentation
• Obtaining additional information regarding source of wealth or source of funds
• Conducting enhanced background and screening checks
• Obtaining additional information regarding the purpose and nature of the relationship
• Applying enhanced ongoing monitoring
• Obtaining appropriate internal approval before establishing or continuing a relationship

The measures applied will depend on the circumstances and level of risk identified.

7. Politically Exposed Persons (PEPs)

FinZuro conducts appropriate screening to identify customers and relevant connected persons who may be classified as politically exposed persons, as well as other persons presenting elevated financial crime risk.

Where applicable, enhanced measures may include obtaining additional information concerning the customer's source of wealth and source of funds, obtaining appropriate approval, and applying enhanced ongoing monitoring.

PEP status does not automatically prevent an individual from becoming a customer. The relationship will be assessed in accordance with applicable requirements and FinZuro's risk-based procedures.

8. Sanctions Screening

FinZuro maintains procedures designed to identify and manage exposure to applicable financial sanctions and sanctions-related risks.

Depending on the circumstances, screening may be conducted against customers, beneficial owners, controllers, authorized persons, transactions, counterparties, and other relevant parties.

Where a potential sanctions match or other sanctions concern is identified, activity may be delayed, restricted, suspended, or declined while appropriate checks are completed.

FinZuro will take action where required by applicable sanctions laws, regulatory requirements, or other applicable legal obligations.

9. Ongoing Customer Due Diligence

Customer due diligence does not end when an account is opened.

FinZuro may review customer information from time to time and may conduct additional reviews when there is a relevant change in circumstances or an event that requires reassessment.

Reviews may include:

• Updating identification and account information
• Reviewing ownership and control information
• Reassessing customer risk
• Reviewing source of funds or source of wealth information where appropriate
• Re-screening relevant persons
• Reviewing account and transaction activity

Customers are expected to provide accurate and current information and to notify us of material changes where required.

10. Transaction Monitoring

FinZuro maintains processes designed to identify unusual, suspicious, or potentially inconsistent activity.

Depending on the circumstances, monitoring may consider:

• Deposits and withdrawals
• Transaction and account activity
• Activity inconsistent with the customer's known profile
• Unusual or complex activity
• Activity involving higher-risk jurisdictions or counterparties
• Attempts to circumvent applicable controls
• Unusual third-party activity
• Activity involving potentially suspicious payment patterns
• Other activity that may present financial crime concerns

Where activity raises concerns, FinZuro may request additional information or documentation and may take appropriate action in accordance with applicable requirements.

11. Suspicious Activity

Where FinZuro identifies activity that may give rise to reasonable concerns regarding money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud, or other financial crime, the matter may be referred for further internal review.

Where required by applicable law, FinZuro may make appropriate reports or disclosures to the relevant competent authorities.

We may restrict, suspend, decline, or terminate a customer relationship or transaction where permitted or required by applicable law or our internal procedures.

To the extent permitted or required by law, FinZuro will not disclose information that could prejudice an investigation, compromise financial crime controls, or improperly reveal the existence or consideration of a suspicious activity report or other confidential regulatory disclosure.

12. Source of Funds and Source of Wealth

FinZuro may request information or documentation to understand the source of funds used in connection with a customer relationship and, where appropriate, the customer's overall source of wealth.

Supporting information may include, depending on the circumstances:

• Bank statements
• Employment or income information
• Business or corporate records
• Tax documentation
• Investment or asset records
• Other reasonable supporting documentation

The information requested will depend on the customer's circumstances and the level of risk identified.

13. Restricted or Prohibited Relationships

FinZuro may decline applications, restrict services, suspend activity, or terminate relationships where:

• Required KYC information cannot be obtained or verified
• A customer provides false or misleading information
• Applicable legal or regulatory requirements cannot be satisfied
• A sanctions concern cannot be resolved
• The relationship presents unacceptable financial crime risk
• The intended use of our services is inconsistent with our policies or applicable law
• We are otherwise required or permitted to do so under applicable requirements

We may also apply geographic, product, customer, transaction, or other restrictions based on applicable laws, regulations, sanctions, regulatory requirements, or our internal risk assessment.

14. Third-Party Service Providers

FinZuro may use specialized third-party providers to support our compliance framework.

These providers may assist with:

• Identity verification
• Document verification
• Sanctions screening
• PEP screening
• Fraud prevention
• Risk assessment
• Transaction monitoring
• Other compliance-related services

Where third parties process information on our behalf, we take appropriate steps to ensure that information is handled securely and in accordance with applicable requirements.

15. Record Keeping

FinZuro maintains appropriate records relating to customer identification, due diligence, transactions, compliance reviews, and other relevant information.

Records are retained for the periods required by applicable laws and regulations and may be retained for longer where necessary to establish, exercise, or defend legal claims or to meet other legitimate regulatory or business requirements.

Information is stored and handled using appropriate security measures.

16. Customer Responsibilities

Customers are responsible for providing accurate, complete, and up-to-date information.

Customers may be required to:

• Provide valid identification and supporting documentation
• Respond to reasonable compliance requests
• Provide information concerning source of funds or source of wealth when requested
• Keep personal and account information current
• Provide updated ownership or control information where applicable
• Cooperate with ongoing verification and compliance reviews

Failure to provide requested information may result in restrictions on an account or services.

17. Confidentiality and Data Protection

Information collected as part of our KYC and AML procedures is handled in accordance with our Privacy Policy and applicable data protection requirements.

We take appropriate technical and organizational measures to protect customer information against unauthorized access, disclosure, alteration, loss, or misuse.

For further information about how we collect and process personal information, please refer to our Privacy Policy.

18. Employee Training and Compliance

FinZuro maintains appropriate internal procedures designed to ensure that relevant employees and personnel understand their responsibilities relating to financial crime prevention.

Relevant personnel may receive training concerning:

• KYC and customer due diligence
• AML/CFT/CPF requirements
• Sanctions
• Fraud prevention
• Suspicious activity indicators
• Internal escalation procedures
• Applicable legal and regulatory requirements

Our compliance framework is subject to appropriate oversight and periodic review.

19. Policy Review

This policy is reviewed periodically and may be updated to reflect changes in applicable laws, regulations, regulatory guidance, financial crime risks, technology, or our business activities.

FinZuro may also update its procedures where changes are necessary to strengthen our financial crime prevention framework.

20. Contact

If you have questions regarding our KYC or AML procedures, please contact us:

Email: support@finzuro.com

Please note that, for security and compliance reasons, we may not be able to provide information concerning internal monitoring, investigations, screening processes, risk thresholds, or suspicious activity reviews.