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

Updated as of January 10,2023

This Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “AML/KYC Policy”) of Mirai Limited, a company duly incorporated under the laws of Malta with company registration number C 100074 and having its registered office at AVENUE 77 Block E Level 2, COMMERCE STREET, ZONE 3, CENTRAL BUSINESS DISTRICT, BIRKIRKARA, CBD 3010, MALTA (hereinafter referred to as “Company”), and represented in the British Economic Area under Mirai Flights Ltd. C/O Cpp, Company number 13395908, Chartered Accountants, 79 Essex Road, London, United Kingdom, N1 2SF, is designated to prevent and mitigate, so far as is possible within the remit of Maltese and EU law, any possible risks of the Company being involved in any kind of illegal activity.

1. Both international and local regulations, as well as the Company`s agreements and policies require that the Company implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, the use of the proceeds of a criminal activity in a transaction, drug and human trafficking, proliferation of weapons of mass destruction, corruption, bribery and consider international sanctions (and other restrictive measures, as may be applicable) and to take action in case of any form of suspicious activity from its clients.

VERIFICATION PROCEDURES

1. The Company shall adopt a risk-based approach in identifying and assessing the money laundering/terrorist financing risks which it may be exposed to, and adapt their measures, policies, controls and procedures as may be required to ensure its resources are utilised where most needed.
2. The Company is to carry out sanction screening on the names of all customers, directors/administrators and/or beneficial owners, as may be applicable, against sanctions’ lists and other adverse media, via reputable commercial databases. The Company is to also adhere to and follow any new sanctions or other restrictive measures which may be imposed and keep abreast of any guidance, notices, decisions, recommendations or rulings that may be issued by the Sanctions Monitoring Board, in terms of the National Interest (Enabling Powers) Act (Act XX of 1993, as subsequently amended).
3. One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, the Company is to establish its own identification and verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks and in terms of local and EU legislation.
4. The Company`s identity verification procedure requires the Client to provide the Company with reliable, independent source documents, data and/or information (e.g., national ID, international passport). For such purposes the Company reserves the right to collect the Client’s identification information for the AML/KYC Policy purposes.
5. The Company will take steps to confirm the authenticity of documents and information provided by the Client. All legal methods for double- checking identification information will be used and the Company reserves the right to request further information and/or documentation from the Client who has been determined to be risky or suspicious.
6. The Company reserves the right to verify the Client’s identity in an on- going basis, especially when the Client’s activity seems to be suspicious (unusual for the particular Client). In addition, the Company reserves the right to request up-to-date documents from the Client, even though the Client passed identity verification in the past. The Company shall also be required to carry out ongoing monitoring and transaction monitoring in terms of its obligations established in terms of Maltese and EU law.
7. Client’s identification information will be collected, stored, shared and protected strictly in accordance with Company`s Privacy Policy and related regulations.
8. Once the Client’s identity has been verified, the Company will be able to absolve itself of 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 towards money laundering and terrorist financing activities. The Company defines the term “money laundering” as “the process through which the illegal nature of criminal proceeds are concealed or disguised in order to give a legitimate appearance to these illegal proceeds”. This AML/KYC Policy also refers and adheres to the definition of “money laundering” as defined in the Prevention of Money Laundering Act (Legal Notice XIX of 1994, as subsequently amended).
2. All the Company`s Clients shall undertake to comply with this AML/KYC Policy and with all applicable local and EU anti-money laundering, countering the funding of terrorism and sanctions laws and regulations. Failure to comply can result in severe consequences such as criminal penalties and heavy fines.
3. The Company shall ensure complete compliance with laws pertaining to anti money laundering through this AML/KYC Policy.
4. All Clients acknowledge, undertake and agree to the following terms regarding their use of the mobile application Mirai Limited (through Mirai Flights trademark) and mirai.flights. website (collectively referred to as the “Service” and/or “Services”):
   1. The Client will comply (throughout his/her time as the Company`s client) with all relevant statutes, laws and regulations pertaining to money laundering, funding of terrorism and sanctions.
   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 any money laundering and/or terrorist financing activities regardless of the location of such activity.
   3. The Client agrees to lend full cooperation to the Company with respect to its anti-money laundering efforts and to provide documentation as may from time-to-time be required in terms of the Company’s requests in order to fulfill its AML/CFT obligations. This includes, inter alia, the provision of documentation and/or information by the Client to the Company for the purpose of assisting it in the performance of its duties as dictated by the applicable laws and regulation regardless of jurisdiction.
   4. The Company reserves the right to delay or stop the provision of any Services contracted by the Client , and/or any subscriptions to any Service to the Client if the Company has reason to believe that any transaction may result in the violation of any applicable law or is contrary to acceptable practices. The Company may also delay or stop the provision of any Services, and/or any subscriptions to any Service to the Client if it is known, or suspected that the Client may have been, is, or may be engaged in money laundering and/or funding of terrorism activities.
   5. The Company may use the Client information for the investigation and/or prevention of fraudulent or otherwise illegal activities.
   6. The Company has the right to share the Client information with:
      A. Investigative agencies or any authorized officers 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 offers to its Clients;
      C. Government, law enforcement agencies and courts;
      D. Regulatory bodies and financial institutions..

   This right to share shall be made after the Company’s Money Laundering Reporting Officer/designated employee has considered an internal report made by an employee of the Company, which was submitted together with all accompanying documentation in relation to such internal report.

   Such right to share shall be exercised after considering such internal report and when the Company’s Money Laundering Reporting Officer/designated employee knows/suspects/has reasonable grounds to suspect that: i) a transaction or an attempted transaction may be related to money laundering or funding of terrorism; or ii) a person may have been/is/may be connected with money laundering or funding of terrorism; or iii) money laundering or funding of terrorism has been/is being/may be committed/attempted.

   Such Client information and the fact that the information has been, will be, or may be shared for the purpose of a possible or actual investigation, as per Clause 6 hereinabove, shall not be disclosed by the Company to the Client.

5. The Company adopts three stages of Client verification process to ensure stricter anti-money laundering activity:
   A. Know-Your-Customer measure - the Company shall identify the Client prior to providing Services. However, the Company retains a right to require the Client to periodically review the documentation and information provided if at any time, the Company believes that information provided is incomplete or inaccurate or if the Company believes that somebody stole your Account credentials, or in terms of its obligations to carry out ongoing monitoring in terms of Section 5(C) below;
   B. Verification - AML verification of Client`s information and the payment data. The Client shall undergo an AML verification process of all documents provided, together with confirming source of wealth and source of funds, where applicable, to ensure its origin;
   C. Ongoing Monitoring - Throughout the business relationship with the Client, the Company shall carry out ongoing monitoring on the Client, through transaction monitoring and the maintenance of information, documentation and data of the Client.

KNOW YOUR CUSTOMER (KYC) AND AML VERIFICATION

1. The Client acknowledges that he/she/it is to complete a KYC check before the subscription to the Service, which must be in form and substance satisfactory to the Company. The KYC check is to be carried out prior to the provision of and Services by providing necessary information with regard to identification of the Client, beneficial owner, origin of wealth and, where applicable, the 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 official name and surname, date and place of birth, nationality, passport/identity card number, issue and expiry dates, country of issue, permanent residential address (including the postcode) and Client’s signature;
   2. For a corporate Client: a high-resolution copy of constituent documents, such as Certificate of Incorporation, and, where applicable, Certificate of Change of Name, Certificate of Good Standing, Articles of incorporation/other constitutive document, etc, indicating the official full name of the entity, the registration number, the date of incorporation/registration; and the registered office or principal place of business.
3. The Client shall undertake 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 specifying a reason for the rejection.