Anti-Money Laundering and Know Your Customer Policy of Mirai Limited

Updated from January 10,2023

1. This Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “AML/KYC Policy”) of Mirai Limited. (hereinafter referred to as “Company”), a company duly incorporated under the laws of Malta having its registered office at AVENUE 77 Block E Level 2, COMMERCE STREET, ZONE 3, CENTRAL BUSINESS DISTRICT, BIRKIRKARA, CBD 3010 reflects main provisions of Company`s compliance policies designated to prevent and mitigate possible risks of the Company being involved in any kind of illegal activity.
2. Both international and local regulations as well as Company`s agreements and policies require from the Company to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Clients.

VERIFICATION PROCEDURES

1. One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, the Company establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.
2. Company`s identity verification procedure requires the Client to provide the Company with reliable, independent source documents, data or information (e.g., national ID, international passport). For such purposes the Company reserves the right to collect Client’s identification information for the AML/KYC Policy purposes.
3. The Company will take steps to confirm the authenticity of documents and information provided by the Clients. All legal methods for double-checking identification information will be used and the Company reserves the right to investigate certain Clients who have been determined to be risky or suspicious.
4. The Company reserves the right to verify Client’s identity in an on-going basis, especially when their activity seemed to be suspicious (unusual for the particular Client). In addition, the Company reserves the right to request up-to-date documents from the Clients, even though they have passed identity verification in the past.
5. Client’s identification information will be collected, stored, shared and protected strictly in accordance with Company`s Privacy Policy and related regulations.
6. Once the Client’s identity has been verified, the Company is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

ANTI-MONEY LAUNDERING POLICY

1. The Company enforces a strict anti-money laundering policy with zero tolerance for money laundering activities. We define money laundering as any activity that is carried out in an attempt to misrepresent the source of funds actually acquired through illegal processes as funds that were acquired through lawful sources/activities.
2. All Company`s clients are obligated to comply with this anti-money laundering policy and with all applicable anti-money laundering laws. Failure to comply can result in severe consequences such as criminal penalties and heavy fines.
3. The Company ensures complete compliance with laws pertaining to anti money laundering through its related policy.
4. All Clients acknowledge, undertake and agree to the following terms regarding their use of the Mirai Platform and website:
   1. The Client will comply (throughout the time as a Company`s client) with all relevant statutes pertaining to money laundering and proceeds from criminal activities.
   2. The Company operates under certain obligations known as “know-your- client” obligations which grant the Company with the right to implement anti-money laundering procedures to help detect and prevent money laundering activities where money laundering may mean to handle any funds associated with any illegal activity regardless of the location of such activity.
   3. The Client agrees to lend full cooperation to the Company with respect to anti-money laundering efforts. This involves providing information that the Company requests to help the Company to perform its duties as dictated by Applicable laws regardless of jurisdiction.
   4. The Company reserves the right to delay or stop any services provision, any subscriptions to Mirai Platform if there is reason to believe that any transaction may result in the violation of any applicable law or is contrary to acceptable practices.
   5. The Company has the right to use client information for the investigation and/or prevention of fraudulent or otherwise illegal activities.
   6. The Company has the right to share client information with:
      A. Investigative agencies or any authorized officers who are helping the Company to comply with applicable law, including anti-money laundering laws and know-your-client obligations;
      B. Organizations that help the Company to provide the services it offer to its clients;
      C. Government, law enforcement agencies and courts;
      D. Regulatory bodies and financial institutions.
5. The Company adopts two stages of Client verification process to ensure stricter anti-money laundering activity:
   A. Know-your customer measure. It shall be passed only once. However, the Company retains a right to require you to pass through it at any time if the Company believes that information you provided before is incomplete or inaccurate or if the Company believes that somebody stole your Account credentials.
   B. AML verification of Client`s payment data. Client shall pass through AML verification of Client`s documents, confirming source of funds to ensure its origin.

KNOW YOUR CUSTOMER (KYC) AND AML VERIFICATION

1. The Client acknowledges that he/she/it has to complete a KYC check before the subscription to Mirai Platform, which must be in form and substance satisfactory to the Company. KYC check is carried out during your use of the Service by providing necessary information with regard to identification of the Client, beneficial owner and origin of the funds, the scope and type of information depending on the type of Client.
2. Appropriate documents for verifying the identity of Client include, but are not limited to, the following:
   1. For an individual Client: a high resolution scanned copy or photo of pages of a passport or, for citizens of EU, any other national ID, indicating family name and name(s), date and place of birth, passport number, issue and expiry dates, country of issue and Client’s signature.;
   2. For a corporate Client: a high-resolution copy of documents showing the existence of the entity, such as Certificate of Incorporation, and, where applicable, Certificate of Change of Name, Certificate of Good Standing, Articles of incorporation, etc.
3. The Client is obliged to collaborate with regard to the AML/ KYC check and to provide any information and document deemed necessary by the Company.
4. The Company may reject any Client in its sole discretion without being obliged to disclose any reason for the rejection.