GLOBAL ANTI-MONEY LAUNDERING ("AML") PROGRAM

Money laundering is defined as the process where the identity of the proceeds of crime is so disguised that it gives an impression of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firms’ knowledge or suspicion.

Jamii-Exchange fully complies with the AML obligations. Jamii-Exchange has implemented systems and procedures that meet the standards set forth by the national and international AML regulations. The company’s AML policy and procedures are designed to prevent money laundering and to impede criminals to launder proceeds of crime.

GLOBAL ANTI-MONEY LAUNDERING (AML) POLICY:

Jamii-Exchange’s AML Policy is designed to prevent money laundering by meeting the global standards on combating money laundering and terrorism financing, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:

1. Appointing a Money Laundering Reporting Officer (MLRO) who has a sufficient level of seniority and independence, and who has responsibility for oversight of compliance with the relevant legislation, regulations, rules and industry guidance;

2. Establishing and maintaining a Risk-Based Approach (RBA) to the assessment and management of money laundering and terrorist financing risks faced by the firm;

3. Establishing and maintaining risk-based Customer Due Diligence (CDD), identification, verification and Know Your Customer (KYC) procedures, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs);

4. Establishing and maintaining risk-based systems and procedures for the monitoring of on-going customer activity;

5. Establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;

6. Maintaining appropriate records for the minimum prescribed periods;

7. Providing training for and raising awareness among all relevant employees.

ONBOARDING VERIFICATION / KYC POLICY:

KYC is done on every customer (proof of identity)

The onboarding process is designed to allow Jamii-Exchange to gather information on potential customers and to detect any possible redflags. The customer must:

1. Provide identification documents, which are then verified

2. Provide a Selfie (the customer must take a photo).

In addition, Jamii-Exchange deploys a screening system against sanctions lists, PEP and adverse media. This ensures a global coverage of sanctions and watch-lists. Jamii-Exchange leverages the system to review new clients, as well as to monitor the existing client base.

If the participant has any questions about the Privacy Policy or the collection and use of information by Jamii-Exchange, it should contact the Data Protection Officer: info@jamii-exchange.com.