Anti-Money Laundering Policy

1. Introduction & Commitment

Aether Capital Group Ltd ("AetherTrade Pro") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. We recognise that money laundering and terrorist financing are serious criminal offences that cause significant harm to society and the financial system.

We have implemented a comprehensive AML/CTF programme designed to detect, prevent and report suspicious activity in accordance with all applicable laws and regulations. All employees, contractors and agents of AetherTrade Pro are required to comply with this policy.

2. Legal Obligations

Our AML compliance programme is based on the following regulatory frameworks:

• Financial Action Task Force (FATF) 40 Recommendations
• The 6th EU Anti-Money Laundering Directive (6AMLD)
• The Proceeds of Crime Act 2002 (POCA)
• The Terrorism Act 2000 and Counter-Terrorism and Border Security Act 2019
• FATF Guidance on Virtual Assets and Virtual Asset Service Providers
• Applicable national financial intelligence unit (FIU) regulations
• UN Security Council Sanctions Resolutions

3. Know Your Customer (KYC) Procedures

3.1 Customer Due Diligence (CDD)

Before activating any account, we conduct standard Customer Due Diligence (CDD) which includes:

• Identity verification: Verifying the identity of every customer using reliable, independent documentary evidence
• Address verification: Confirming the customer's residential address through supporting documentation
• Sanctions screening: Screening all customers against applicable sanctions lists including OFAC, UN, EU and national lists
• PEP screening: Identifying Politically Exposed Persons and applying enhanced due diligence
• Adverse media screening: Reviewing publicly available information for red flags

3.2 Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied to higher-risk customers and relationships, including:

• Politically Exposed Persons (PEPs) and their close associates
• Customers from high-risk jurisdictions as identified by FATF
• Customers with complex ownership structures
• Transactions or customer profiles presenting elevated risk indicators
• Large or unusual transactions requiring source of funds documentation

EDD measures include senior management approval, enhanced monitoring, source of wealth verification and more frequent account reviews.

3.3 Simplified Due Diligence (SDD)

Simplified due diligence may be applied in low-risk scenarios as permitted by applicable law, subject to our risk assessment framework and documented rationale.

3.4 Ongoing Monitoring

We continuously monitor customer accounts and transactions to detect unusual patterns, including:

• Unusual transaction volumes or frequencies inconsistent with customer profile
• Transactions involving high-risk jurisdictions or sanctioned entities
• Structuring activity designed to avoid reporting thresholds
• Rapid layering of funds across multiple accounts
• Withdrawal requests shortly after deposit without apparent investment activity

4. Risk Assessment Framework

We adopt a risk-based approach to AML compliance, assessing risk across four dimensions:

5. Suspicious Activity Reporting

We have a legal obligation to report suspicions of money laundering or terrorist financing to the relevant Financial Intelligence Unit (FIU). Our procedures include:

• Internal reporting: All staff must report suspicions to the designated Money Laundering Reporting Officer (MLRO) immediately
• MLRO review: The MLRO assesses all internal reports and determines whether to file a Suspicious Activity Report (SAR)
• SAR filing: SARs are filed with the relevant authority within the required timeframes
• Tipping off prohibition: We are legally prohibited from informing a customer that a SAR has been or may be filed in relation to them
• Confidentiality: All suspicious activity reports and related investigations are strictly confidential

6. High-Risk Jurisdictions

We do not accept customers from, or process transactions involving, jurisdictions subject to comprehensive sanctions programmes or identified as high-risk by relevant authorities including:

• Countries on the FATF "black list" (High-Risk Jurisdictions subject to a Call for Action)
• Countries subject to comprehensive UN, EU or OFAC sanctions
• Jurisdictions identified as non-cooperative in international AML/CFT efforts

The list of restricted jurisdictions is reviewed and updated regularly in line with regulatory guidance.

7. Blockchain Analytics & Transaction Monitoring

Given the digital asset nature of our platform, we employ specialist blockchain analytics tools to:

• Trace the origin of incoming cryptocurrency deposits
• Identify transactions linked to known illicit addresses (darknet markets, ransomware, mixers)
• Assess the risk score of incoming and outgoing transactions
• Monitor for wallet clustering and attribution patterns

Deposits from high-risk blockchain sources will be rejected and may be reported to authorities.

8. Record Keeping

We maintain comprehensive records of all AML activities in accordance with regulatory requirements:

• Customer identification documents: 5 years after account closure
• Transaction records: 7 years from the date of the transaction
• Internal and external suspicious activity reports: 7 years
• Risk assessments and compliance reviews: 7 years

All records are stored securely and made available to competent authorities upon request.

9. Training & Awareness

All staff with customer-facing or compliance responsibilities receive regular AML/CTF training covering:

• Recognition of money laundering and terrorist financing red flags
• Internal reporting procedures and obligations
• Legal obligations and penalties for non-compliance
• Updates to regulatory requirements and typologies

10. Non-Compliance Consequences

Users who are found to have engaged in or attempted money laundering, terrorist financing or any other financial crime through our Platform will face:

• Immediate account suspension and termination
• Freezing of all account balances pending investigation
• Reporting to relevant law enforcement and financial intelligence authorities
• Potential civil and criminal prosecution
• Permanent ban from the Platform

11. Contact — Money Laundering Reporting Officer