Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Atlas Market Exchange is committed to the highest standards of Anti-Money Laundering (AML) compliance and the prevention of financial crime. This policy sets out our approach to detecting, preventing, and reporting money laundering, terrorist financing, and other forms of financial crime in accordance with applicable laws and regulations.

As a fully licensed Danish bank operating under the supervision of the Danish Financial Supervisory Authority (FSA), Atlas Market Exchange is legally obligated to implement robust AML and Know Your Customer (KYC) procedures. We operate in compliance with the European Union's Anti-Money Laundering Directives (AMLD), the Financial Action Task Force (FATF) recommendations, and all other applicable national and international AML regulations.

This policy applies to all clients, employees, partners, and third-party service providers associated with Atlas Market Exchange. All individuals and entities that wish to open an account or use our services must comply with the requirements set out in this policy.

Atlas Market Exchange has a zero-tolerance policy towards money laundering, terrorist financing, and any other form of financial crime. Any attempt to use our platform for such purposes will result in immediate account suspension, reporting to relevant authorities, and full cooperation with law enforcement investigations.

1. Purpose and Scope

The purpose of this AML & KYC Policy is to:

• Establish clear procedures for the identification and verification of all clients and beneficial owners.
• Define the standards for ongoing monitoring of client accounts and transactions.
• Set out the process for detecting and reporting suspicious activities to the relevant authorities.
• Ensure full compliance with all applicable AML laws, regulations, and guidelines.
• Protect Atlas Market Exchange, its clients, and the integrity of the global financial system from the risks of money laundering and terrorist financing.

This policy applies to all business relationships and occasional transactions conducted through Atlas Market Exchange, regardless of the client's country of residence or the financial product being used.

2. What is Money Laundering?

Money laundering is the process by which individuals or organisations attempt to disguise the proceeds of criminal activity as legitimate funds. It typically involves three stages:

• Placement: The introduction of illegally obtained funds into the financial system, for example by depositing cash into a bank account or purchasing financial instruments.
• Layering: The process of distancing the funds from their criminal origin through a series of complex financial transactions, transfers, or conversions designed to obscure the audit trail.
• Integration: The final stage, in which the laundered funds are reintroduced into the legitimate economy and appear to be derived from lawful sources.

Terrorist financing involves the collection, transfer, or use of funds — whether from legitimate or illegitimate sources — to support terrorist activities. Both money laundering and terrorist financing are serious criminal offences under applicable law, and Atlas Market Exchange is legally obligated to take all reasonable steps to prevent its platform from being used for such purposes.

3. Know Your Customer (KYC) Requirements

Atlas Market Exchange applies rigorous KYC procedures to all clients before and during the business relationship. KYC is the process by which we verify the identity of our clients and assess the risks associated with the business relationship. Our KYC requirements include the following:

3.1 Identity Verification

All clients are required to provide satisfactory proof of identity before an account can be opened or any services can be provided. Accepted forms of identity documentation include:

• A valid government-issued passport.
• A national identity card issued by a recognised government authority.
• A valid driving licence containing the client's full name, photograph, and date of birth.

All identity documents must be current, undamaged, and clearly legible. Copies of documents may be required to be certified by an appropriate authority. Atlas Market Exchange reserves the right to request additional forms of identity verification at any time during the course of the business relationship.

3.2 Address Verification

All clients must provide satisfactory proof of their current residential address. Accepted forms of address verification include:

• A utility bill (gas, electricity, water, or internet) issued within the last three months.
• A bank statement issued within the last three months showing the client's name and residential address.
• An official government correspondence or tax document issued within the last twelve months.
• A mortgage statement or tenancy agreement issued within the last twelve months.

3.3 Source of Funds and Wealth

Depending on the nature of the account activity and the applicable risk assessment, clients may be required to provide documentation to verify their source of funds and source of wealth. This may include:

• Recent payslips or an employment contract confirming income.
• Bank statements demonstrating the origin of deposited funds.
• Evidence of business ownership or income from self-employment.
• Documentation relating to the sale of assets, inheritance, or other capital events.
• Tax returns or financial statements where applicable.

3.4 Beneficial Ownership

Where a client is a legal entity such as a company, trust, or partnership, Atlas Market Exchange is required to identify and verify the ultimate beneficial owners (UBOs) of that entity — typically any individual who owns or controls 25% or more of the entity. Corporate clients will be required to provide:

• Certificate of incorporation or equivalent registration documentation.
• Memorandum and articles of association or equivalent constitutional documents.
• Register of directors and shareholders.
• Proof of identity and address for all directors and beneficial owners.
• Any other documentation required to establish the ownership and control structure of the entity.

4. Risk-Based Approach

Atlas Market Exchange applies a risk-based approach to AML and KYC compliance. This means that the level of due diligence applied to each client and business relationship is proportionate to the assessed level of money laundering and terrorist financing risk. Our risk assessment considers factors including:

• The client's country of residence and the jurisdictions with which they are associated.
• The nature, size, and frequency of the client's transactions and account activity.
• The type of financial products and services being used.
• The client's occupation, business type, and source of funds.
• Whether the client is a Politically Exposed Person (PEP) or is associated with a PEP.
• Whether the client is subject to international sanctions or appears on any sanctions lists.

4.1 Standard Due Diligence (SDD)

Standard Due Diligence is applied to the majority of clients who present a low to medium risk of money laundering or terrorist financing. SDD includes identity verification, address verification, and basic source of funds assessment.

4.2 Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied to clients who present a higher risk of money laundering or terrorist financing. EDD may be triggered by the following factors:

• The client is a Politically Exposed Person (PEP) or is closely associated with a PEP.
• The client is resident in or associated with a high-risk jurisdiction as identified by the FATF or relevant regulatory authorities.
• The client's transaction volumes or account activity are unusually high or inconsistent with their stated profile.
• The client operates a cash-intensive business or is involved in industries considered higher risk for financial crime.
• The nature of the business relationship or the transaction raises specific concerns about potential money laundering or terrorist financing.

EDD measures may include obtaining additional documentation, conducting enhanced background checks, requiring senior management approval for the business relationship, and applying more frequent ongoing monitoring.

4.3 Simplified Due Diligence (SDD)

In limited circumstances where the risk of money laundering or terrorist financing is assessed as low, Atlas Market Exchange may apply Simplified Due Diligence. This is subject to the conditions set out in applicable AML regulations and does not exempt the Company from its obligation to monitor transactions on an ongoing basis.

5. Politically Exposed Persons (PEPs)

A Politically Exposed Person (PEP) is an individual who holds or has held a prominent public position, such as a head of state, government minister, senior judicial official, senior military officer, or executive of a state-owned enterprise. Immediate family members and known close associates of PEPs are also subject to enhanced scrutiny.

Atlas Market Exchange screens all clients against PEP databases as part of the onboarding process and on an ongoing basis. Where a client is identified as a PEP or as closely associated with a PEP, the following measures will be applied:

• Enhanced Due Diligence will be conducted, including additional verification of the source of funds and source of wealth.
• Senior management approval will be required before establishing or continuing the business relationship.
• The account will be subject to enhanced ongoing monitoring throughout the duration of the business relationship.

6. Sanctions Screening

Atlas Market Exchange conducts sanctions screening on all clients, beneficial owners, and associated parties as part of the onboarding process and on an ongoing basis. We screen against the following sanctions lists and databases, including but not limited to:

• United Nations (UN) Security Council Consolidated Sanctions List.
• European Union (EU) Consolidated Sanctions List.
• United States Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List.
• United Kingdom (UK) HM Treasury Consolidated Sanctions List.
• Danish Financial Supervisory Authority (FSA) and other relevant national sanctions databases.

If a client or associated party is identified as a sanctioned individual or entity, Atlas Market Exchange will immediately freeze the relevant account, decline to process any transactions, and report the matter to the appropriate regulatory and law enforcement authorities in accordance with applicable law.

7. Ongoing Monitoring

KYC verification is not a one-time process. Atlas Market Exchange conducts ongoing monitoring of all client accounts and transactions throughout the duration of the business relationship. Ongoing monitoring includes:

• Transaction Monitoring: Continuous analysis of client transactions to detect patterns or activities that are inconsistent with the client's known profile, stated purpose of the account, or expected transaction behaviour.
• Periodic Review: Regular review of client KYC documentation and risk assessments to ensure that the information held is accurate, up to date, and reflective of the current risk profile of the client.
• Trigger-Based Reviews: Ad hoc reviews initiated when specific events or changes occur, such as a significant increase in transaction volumes, a change in the client's country of residence, or the identification of a potential connection to a sanctioned party or PEP.
• Document Refresh: Clients may be required to submit updated identity and address documentation at intervals determined by our compliance team based on the applicable risk assessment.

8. Suspicious Activity Reporting

Atlas Market Exchange has a legal obligation to report suspicious activities to the relevant financial intelligence units and law enforcement authorities. Our internal reporting procedures include:

• All employees are required to report any suspicion of money laundering, terrorist financing, or other financial crime to the designated Money Laundering Reporting Officer (MLRO) without delay.
• The MLRO is responsible for reviewing internal suspicious activity reports and determining whether a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) should be filed with the relevant authority.
• Atlas Market Exchange will file SARs and STRs with the Danish Financial Intelligence Unit (FIU) and any other relevant authority as required by applicable law.
• Clients must not be informed that a suspicious activity report has been filed or that they are under investigation, as this would constitute "tipping off", which is a criminal offence under applicable AML legislation.

Examples of activities that may trigger a suspicious activity report include, but are not limited to:

• Transactions that are unusually large or have no apparent legitimate business purpose.
• Unusual patterns of transactions, such as structuring transactions to avoid reporting thresholds.
• Deposits or withdrawals that are inconsistent with the client's known financial profile or account activity.
• Requests to transfer funds to or from high-risk jurisdictions without a clear business rationale.
• Clients who are reluctant to provide required KYC documentation or who provide false or misleading information.
• Transactions that appear to be linked to sanctioned individuals, entities, or countries.

9. Record Keeping

Atlas Market Exchange maintains comprehensive records of all KYC documentation, transaction records, and AML-related activities in accordance with applicable law. Our record-keeping obligations include:

• All KYC documentation obtained during the onboarding process and throughout the business relationship is retained for a minimum of five years following the termination of the business relationship.
• Records of all transactions, including the nature, amount, currency, and date of each transaction, are retained for a minimum of five years.
• All internal suspicious activity reports and filed SARs or STRs are retained for a minimum of five years.
• Records of all risk assessments, due diligence activities, and compliance reviews are maintained and available for inspection by regulatory authorities upon request.

10. Employee Training and Awareness

Atlas Market Exchange is committed to ensuring that all employees who are involved in client-facing activities, compliance functions, or transaction processing are adequately trained in AML and KYC obligations. Our training programme includes:

• Mandatory AML and KYC training for all new employees as part of the onboarding process.
• Regular refresher training to ensure that all employees are kept up to date with changes in AML legislation, regulatory guidance, and internal policies and procedures.
• Specific training for employees in high-risk roles, including compliance officers, account managers, and transaction monitoring teams.
• Regular internal communications and updates on emerging financial crime trends, typologies, and red flags.

All employees have a personal responsibility to be vigilant for signs of money laundering and terrorist financing and to report any concerns to the MLRO promptly. Failure to comply with our AML and KYC obligations may result in disciplinary action, including termination of employment.

11. High-Risk Jurisdictions and Restricted Countries

Atlas Market Exchange does not accept clients from countries or territories that are identified as high-risk by the Financial Action Task Force (FATF), are subject to international sanctions, or where the provision of our services is prohibited by applicable law. Our list of restricted jurisdictions is reviewed and updated regularly in line with FATF guidance, EU and UN sanctions, and the requirements of the Danish Financial Supervisory Authority (FSA).

Clients who become residents of a restricted jurisdiction after opening an account with Atlas Market Exchange may be required to close their account and withdraw their funds. Atlas Market Exchange reserves the right to refuse service, suspend accounts, or terminate business relationships with clients from high-risk or restricted jurisdictions at any time.

12. Non-Compliance and Consequences

Failure to comply with this AML & KYC Policy — whether by a client, employee, or third party — will be treated with the utmost seriousness by Atlas Market Exchange. Consequences of non-compliance may include:

• Refusal to open an account or provide services.
• Suspension or immediate termination of an existing account.
• Freezing of account funds pending regulatory investigation.
• Filing of a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) with the relevant financial intelligence unit or law enforcement authority.
• Full cooperation with regulatory investigations, law enforcement authorities, and judicial proceedings.
• For employees, disciplinary action up to and including termination of employment and referral to relevant professional regulatory bodies.

13. Policy Review and Updates

This AML & KYC Policy is reviewed and updated on a regular basis to ensure that it remains consistent with changes in applicable laws, regulations, regulatory guidance, and industry best practices. Policy reviews are conducted at least annually or whenever significant changes to relevant legislation or regulatory requirements occur.

The most current version of this policy is always available on the Atlas Market Exchange platform and website. Clients are encouraged to review this policy periodically to stay informed of our AML and KYC requirements.

14. Contact Us

If you have any questions about this AML & KYC Policy, require clarification on our verification requirements, or wish to report a concern regarding potential financial crime, please contact us through the following channels:

• Compliance Team: info@atlasmarketexchange.com
• General Support: info@atlasmarketexchange.com
• Client Support: Available through the Platform's live chat and help centre.
• Registered Address: Atlas Market Exchange, Hong Kong.

Atlas Market Exchange is committed to maintaining the highest standards of financial integrity and to working in full cooperation with regulatory authorities to combat money laundering, terrorist financing, and all other forms of financial crime.