ANTI-MONEY LAUNDERING (AML), COUNTER-TERRORIST FINANCING (CFT) & SANCTIONS POLICY

Capital Mint FZCO – February 2026
(“Capital Mint” or the “Company”)

1. Policy Statement

Capital Mint FZCO’s firmly committed to preventing money laundering, terrorist financing, sanctions evasion, and the financing of proliferation of weapons of mass destruction.

The Company adopts a zero-tolerance approach toward illicit financial activity and implements a documented, risk-based compliance framework aligned with:

• UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations
• Cabinet Decision No. 10 of 2019 (Implementing Regulation)
• UAE Federal Law No. 7 of 2014 on Combating Terrorism Crimes
• Applicable United Nations Security Council Resolutions
• UAE Local Terrorist List
• FATF Recommendations
• OFAC sanctions screening standards
• Travel Rule standards applicable to virtual asset transfers

This Policy applies to all customers, employees, officers, contractors, affiliates, and any entity in which Capital Mint holds ownership interest.

2. Business Model & AML Exposure

Capital Mint operates an educational, trading evaluation model whereby:

• Individuals purchase evaluation programs.
• Clients undergo KYC on-boarding upon becoming a funded trader.
• The Company does not accept deposits for trading purposes.
• The Company does not hold or manage client funds.
• Trading capital remains exclusively Company-owned.
• Pay-outs represent contractual performance compensation.

Although Capital Mint does not custody client assets, AML/CFT risks arise from:

• Cross-border fee payments (fiat and crypto)
• Identity misuse
• Chargeback abuse
• Sanctions exposure
• Crypto wallet anonymity and obfuscation techniques

Accordingly, AML obligations apply to on-boarding, payments, and payout processes.

3. Definition of Money Laundering (UAE Jurisdiction)

Pursuant to Article 2 of Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations (United Arab Emirates), money laundering is committed where a person intentionally engages in any of the following acts while knowing that the funds constitute proceeds of a felony or misdemeanour:

1. Transfer or Movement of Proceeds

Transferring or moving the proceeds of crime for the purpose of concealing or disguising their illicit origin.

2. Concealment or Disguise

Concealing or disguising the true nature, source, location, disposition, movement, ownership, or rights relating to the proceeds.

3. Acquisition, Possession, or Use

Acquiring, possessing, or using proceeds of crime upon receipt.

4. Assistance to Offender

Assisting the perpetrator of the predicate offence to evade punishment.

For the purposes of the UAE AML Law:

• “Proceeds” refers to any funds derived directly or indirectly from the commission of a predicate offence.
• A predicate offence includes any felony or misdemeanour under UAE law.
• Money laundering constitutes a criminal offence even where the predicate offence occurred outside the United Arab Emirates, provided the conduct would constitute a crime under UAE law.

Money laundering is an intentional criminal offence. However, failure to report suspicions to the UAE Financial Intelligence Unit (FIU), where required, may give rise to criminal liability.

4. Terrorist Financing

Under UAE Federal Law No. 7 of 2014 and related AML legislation, terrorist financing includes the collection, provision, or use of funds, directly or indirectly, with the knowledge or intent that they will be used to carry out terrorist acts or support terrorist organisations, regardless of whether the funds are linked to a specific act.

5. Regulatory Framework

Capital Mint complies with:

• Federal Decree-Law No. 20 of 2018
• Cabinet Resolution No. 10 of 2019
• Federal Law No. 7 of 2014
• UAE Cybercrime Law No. 5 of 2012
• UAE FIU reporting requirements
• United Nations sanctions implemented in the UAE
• FATF Recommendations
• OFAC sanctions list screening
• Travel Rule standards for virtual asset transfers

While not licensed as a financial institution, Capital Mint adopts standards consistent with regulated entities.

6. Risk-Based Approach

Capital Mint applies a documented risk assessment methodology evaluating:

6.1 Customer Risk

• Nationality and residency
• PEP status
• Sanctions screening results
• Adverse media findings
• Payment method
• Crypto wallet risk score

6.2 Geographic Risk

• FATF High-Risk Jurisdictions
• UAE National Risk Assessment
• UN Sanctions regimes

Restricted jurisdictions are prohibited.

6.3 Product & Transaction Risk

• Frequency of evaluation purchases
• Structuring behaviour
• Chargeback patterns
• Suspicious payout behaviour
• Use of anonymisation tools

6.4 Risk Classification

Clients are classified as:

• Low Risk
• Medium Risk
• High Risk (Enhanced Due Diligence required)

7. Customer Due Diligence (CDD)

Prior to activation:

• Government-issued identification
• Liveness/selfie verification
• Sanctions screening
• PEP screening
• Adverse media screening

Anonymous accounts are strictly prohibited.

8. Enhanced Due Diligence (EDD)

EDD is required where:

• Client is a Politically Exposed Person
• High-risk jurisdiction identified
• Crypto risk score elevated
• Suspicious behaviour observed

EDD measures may include:

• Source of funds declaration
• Additional documentation
• Management approval
• Ongoing enhanced monitoring

9. Sanctions Compliance

All clients are screened against:

• UN Consolidated Sanctions List
• UAE Local Terrorist List
• OFAC SDN List
• EU Consolidated List
• UK HMT Sanctions List

Capital Mint does not engage with:

• Sanctioned individuals or entities
• Comprehensively sanctioned jurisdictions
• Shell banks
• Anonymous counterparties

Confirmed matches result in immediate account suspension and escalation.

The current list of sanctioned countries is the following: Afghanistan, Belarus, Burundi, Central African Republic, Congo Republic, Cuba, Crimea, Democratic Republic of Congo, Eritrea, Guinea, Guinea-Bissau, Iran, Iraq, Liberia, Libya, Myanmar, North Korea, Papua New Guinea, North Korea, Russia, Somalia, South Sudan, Sudan, Syria, Vanuatu, Venezuela, Yemen, and Zimbabwe.

10. Crypto Compliance & Travel Rule

For cryptocurrency transactions:

• Blockchain analytics tools are utilised
• Wallet risk scoring is conducted
• Transactions linked to mixers, ransomware, darknet markets, or sanctioned wallets are rejected
• Travel Rule information is transmitted where counterparties qualify as VASPs

High-risk crypto transactions require Compliance Officer approval.

11. Transaction Monitoring

Monitoring includes:

• Rapid repeat purchases
• Third-party payment attempts
• IP mismatches
• Unusual payout behaviour
• Structuring to avoid thresholds
• Abnormal trading patterns tied to payment irregularities

Both automated systems and manual review are applied.

12. Suspicious Transaction Reporting (STR)

Where reasonable grounds for suspicion exist:

1. Matter is escalated to the AML Compliance Officer.
2. Internal documentation is prepared.
3. An STR is filed with the UAE FIU via go AML where required.
4. Confidentiality is maintained

Failure to report may result in criminal liability.

13. Record Retention

All AML records including:

• KYC documentation
• Screening results
• Risk assessments
• Transaction logs
• STR filings

Are retained for a minimum of five (5) years in accordance with UAE law.

14. Governance & Internal Controls

14.1 AML Compliance Officer

A designated AML Compliance Officer is responsible for:

• AML framework oversight
• STR submission
• Policy updates
• Regulatory liaison
• Internal investigations
• Staff training

14.2 Compliance Testing

Periodic independent testing evaluates:

• Effectiveness of controls
• Screening integrity
• Risk classification consistency

15. Training

Annual AML/CFT training is mandatory and includes:

• Red flag identification
• Sanctions awareness
• Crypto risk indicators
• Escalation procedures
• Legal reporting obligations

Attendance records are maintained.

16. Breaches & Penalties

Non-compliance may result in:

• Account termination
• Internal disciplinary action
• Reporting to authorities
• Cooperation with law enforcement

Under UAE AML Law, penalties may include:

• Fines between AED 100,000 and AED 10,000,000
• Imprisonment up to 10 years

17. On-going Review

This policy may be updated periodically to reflect changes in applicable laws, regulatory expectations, or operational risk assessments.