TABLE OF CONTENTS

• Introduction
• 1. Verification Procedures
  • 1.1. Identity Verification
  • 1.2. Card Verification
• 2. Compliance Officer
• 3. Transaction Monitoring
• 4. Risk Assessment

Introduction

The BIT2ME Anti-Money Laundering and Know Your Customer Policy (hereinafter, the "AML / KYC Policy") is designed to prevent and mitigate the possible risks of BIT2ME being involved in any type of illegal activity.

Both international and local regulations require BIT2ME to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery, and to take action in case of any form of suspicious activity from its users.

The AML / KYC Policy covers the following matters:

• Verification procedures.
• Compliance Officer.
• Transaction monitoring.
• Risk assessment.

1. Verification Procedures

One of the international standards for preventing illegal activity is Customer Due Diligence ("CDD"). According to CDD, BIT2ME establishes its own verification procedures within the standards of anti-money laundering and "Know Your Customer" frameworks.

1.1. Identity Verification

BIT2ME's identity verification procedure requires the User to provide BIT2ME with reliable, independent documents, data, or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes, BIT2ME reserves the right to collect User identification information for the purposes of the AML / KYC Policy.

BIT2ME will take measures to confirm the authenticity of the documents and information provided by the Users. All legal methods will be used to verify identification information, and BIT2ME reserves the right to investigate certain Users who have been determined to be risky or suspicious.

BIT2ME reserves the right to verify the User's identity on an ongoing basis, especially when their identification data has changed or their activity appears suspicious (unusual for the particular User). In addition, BIT2ME reserves the right to request updated documents from Users, even if they have passed identity verification in the past.

User identification information will be collected, stored, shared, and protected strictly in accordance with the BIT2ME Privacy Policy and related regulations.

Once the User's identity has been verified, BIT2ME may be relieved of potential legal liability in a situation where its Services are used for illegal activities.

1.2. Card Verification

Users who are intended to use payment cards in connection with BIT2ME's Services must pass card verification in accordance with the instructions available on the BIT2ME Site.

2. Compliance Officer

The Compliance Officer is the person, duly authorized by BIT2ME, whose duty is to ensure the effective implementation and enforcement of the AML and KYC Policy. It is the Compliance Officer's responsibility to supervise all aspects of BIT2ME's anti-money laundering and counter-terrorist financing, including but not limited to:

1. Collecting users' identification information.
2. Establishing and updating internal policies and procedures for the completion, review, submission, and retention of all reports and records required by applicable laws and regulations.
3. Monitoring transactions and investigating any significant deviations from normal activity.
4. Implementing a records management system for the proper storage and retrieval of documents, files, forms, and records.
5. Updating the risk assessment regularly.
6. Providing law enforcement with the information required under applicable laws and regulations.

The Compliance Officer is entitled to interact with law enforcement, which are involved in the prevention of money laundering, terrorist financing, and other illegal activities.

3. Transaction Monitoring

Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, BIT2ME relies on data analysis as a risk assessment and suspicion detection tool. BIT2ME performs a variety of compliance-related tasks, including data capture, filtering, record keeping, investigation management, and reporting. The system functionalities include:

1. Daily verification of users against recognized "blacklists" (e.g., OFAC), aggregating transfers by multiple data points, placing users on watchlists and service denial lists, opening cases for investigation where necessary, sending internal communications, and completing legal reports, if applicable;
2. Case and document management.

With respect to the AML / KYC Policy, BIT2ME will monitor all transactions and reserves the right to:

• Ensure that transactions of a suspicious nature are reported to the appropriate police through the Compliance Officer.
• Request the User to provide additional information and documents in case of suspicious transactions.
• Suspend or cancel the user's account when BIT2ME reasonably suspects that said user was involved in illegal activities.

The above list is not exhaustive and the Compliance Officer will monitor the Users' transactions on a day-to-day basis to define whether such transactions should be reported and treated as suspicious or if they should be treated as bona fide.

4. Risk Assessment

BIT2ME, in line with international requirements, has adopted a risk-based approach to combat money laundering and terrorist financing. By adopting a risk-based approach, BIT2ME can ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the identified risks. This will allow resources to be allocated in the most efficient way. The principle is that resources should be directed according to priorities so that the greatest risks receive the most attention.