CRUCIAL MARKETS – ANTI-MONEY LAUNDERING (AML) POLICY

Approved By: Board of Directors

1. Introduction & Purpose

Crucial Markets (“the Company”) is committed to preventing financial crime and detecting and reporting suspicious activity that may constitute money laundering, terrorist financing, or other illicit conduct.

This AML Policy establishes the framework to ensure compliance with applicable AML, Counter-Terrorist Financing (CTF), and sanctions laws and regulations.

This Policy applies to all directors, officers, employees, contractors, agents, and third-party service providers acting on behalf of Crucial Markets.

2. Regulatory Scope

This Policy aligns with relevant AML/CTF statutes and regulations in jurisdictions where Crucial Markets operates, including but not limited to:

• Financial Crimes Enforcement Network (FinCEN) rules (US)

• Office of Foreign Assets Control (OFAC) sanctions programs

• EU 6th AML Directive

• FCA, CySEC, ASIC, or other applicable regulatory AML standards

3. Definitions

Money Laundering: The process by which illicit funds are made to appear legitimate.

Customer Due Diligence (CDD): Verification of customer identity and risk assessment measures.

Politically Exposed Person (PEP): Individuals with prominent public functions, including their family members and close associates.

Suspicious Activity Report (SAR): A confidential report submitted to the relevant authority when suspicious transactions are detected.

4. AML Compliance Officer (AMLCO)

The Company shall appoint an AML Compliance Officer responsible for:

• Oversight of AML program implementation

• CDD/KYC monitoring

• SAR/STR reporting

• AML training

• Risk assessments and audits

• Liaising with regulators and law enforcement

5. Customer Identification & Verification

5.1 Onboarding Requirements

Crucial Markets will obtain and verify the following prior to onboarding:

• Full legal name

• Date of birth or registration date

• Residential or business address

• Government-issued photo identification (passport or driver’s license)

• Proof of address (utility bill or bank statement)

• Source of Funds and/or Source of Wealth documentation

5.2 Verification Standards

Verification must occur using reliable and independent documents, data, or information prior to account activation.

Electronic verification tools may be used provided they meet applicable regulatory standards.

6. Risk-Based Customer Due Diligence

Customers shall be risk-rated as follows:

• Low Risk – Verified retail clients from compliant jurisdictions

• Medium Risk – Corporate clients, trust accounts, or more complex structures

• High Risk – PEPs, clients from high-risk jurisdictions, or customers with complex ownership structures

Enhanced Due Diligence (EDD) must be applied where elevated risk indicators are present.

7. Ongoing Monitoring

Customer transactions shall be continuously monitored to detect:

• Unusual transaction volume or patterns

• Structuring to avoid reporting thresholds

• Rapid deposits and withdrawals

• Activity inconsistent with the customer’s profile or expected behavior

Automated AML monitoring systems may be used to identify and flag suspicious activity.

8. Politically Exposed Persons (PEPs)

PEPs must undergo enhanced scrutiny before and after onboarding:

• Verification of identity and source of wealth

• Senior management approval prior to onboarding

• Ongoing enhanced monitoring

9. Reporting Suspicious Activity

Any employee who detects suspicious conduct must immediately report it to the AMLCO.

The AMLCO shall evaluate the activity and, where appropriate, file a Suspicious Activity Report (SAR) with the relevant authorities within required timelines.

10. Recordkeeping

The Company shall retain:

• Customer identification and verification records

• Transaction histories

• AML risk assessments

• SAR/STR documentation

Records must be maintained for a minimum of five to seven years, or longer if required by applicable law.

11. Sanctions Screening

Crucial Markets shall:

• Screen customers against global sanctions lists (including OFAC, UN, and EU lists)

• Block or reject transactions involving sanctioned individuals, entities, or countries

• Report to authorities where required by law

12. Employee Training

All relevant personnel shall complete AML/CTF and sanctions training at least annually. Training shall cover:

• AML fundamentals

• Red-flag indicators

• Reporting procedures

• Regulatory obligations

Training attendance and completion shall be documented and retained.

13. Internal Audit & Program Review

Periodic internal or external audits of the AML program shall occur at least annually to ensure:

• Effectiveness of internal controls

• Compliance with this Policy

• Appropriateness of risk assessments

Updates shall be implemented based on audit findings and regulatory changes.

14. Confidentiality & Non-Retaliation

AML reports and investigations shall remain confidential to the extent permitted by law.

No employee shall suffer retaliation for reporting suspected violations in good faith.

15. Policy Amendments

This AML Policy may be amended by the Board of Directors and shall be reviewed at least annually or when required by applicable law.

ANNEX A: AML RED FLAGS (Examples)

• Source of funds cannot be verified

• Large deposits followed by rapid withdrawals

• Transfers originating from high-risk jurisdictions

• Structuring transactions to avoid reporting thresholds

• Unusual account activity inconsistent with the customer profile