Anti-Money Laundering Policy

1. Policy Statement

Poce Technology Inc. ("Poce Technology," the "Company") is committed to conducting business with the highest standards of integrity and in full compliance with all applicable anti-money laundering ("AML") and counter-terrorist financing ("CTF") laws and regulations. This AML Policy sets forth the framework for our compliance program and applies to all employees, contractors, and agents of the Company.

2. Scope and Applicability

This Policy applies to all Services provided by Poce Technology, including but not limited to cross-border payment processing, multi-currency settlement, digital trade facilitation, and API services. The Policy covers all jurisdictions in which we operate and is designed to comply with applicable AML/CTF requirements including the Bank Secrecy Act (BSA), USA PATRIOT Act, and regulations issued by FinCEN.

3. AML Compliance Officer

The Company has designated an AML Compliance Officer responsible for overseeing the implementation and enforcement of this Policy. The AML Compliance Officer has the authority to report directly to senior management and the Board of Directors on AML compliance matters. Contact: [email protected].

4. Risk Assessment

We conduct regular risk assessments to identify, assess, and mitigate money laundering and terrorist financing risks associated with our Services, customers, geographic footprint, and delivery channels. Risk assessments are reviewed at least annually and upon significant changes to our business model or regulatory environment.

5. Customer Due Diligence (CDD)

We implement risk-based Customer Due Diligence procedures for all customers. Our CDD program includes:

• Identification and Verification: Collecting and verifying customer identification information including legal name, physical address, date of incorporation, and tax identification numbers.
• Beneficial Ownership: Identifying and verifying beneficial owners with 25% or more ownership interest and control persons.
• Nature of Business: Understanding the customer's business activities, expected transaction patterns, and purpose of the account.
• Ongoing Monitoring: Periodic review of customer information and transaction activity to ensure consistency with the customer's risk profile.

6. Enhanced Due Diligence (EDD)

Enhanced Due Diligence measures are applied to higher-risk customers and transactions, including:

• Politically Exposed Persons (PEPs) and their close associates and family members.
• Customers from high-risk jurisdictions identified by FATF or other international bodies.
• Complex or unusually large transactions with no apparent economic or lawful purpose.
• Customers in high-risk industries including virtual asset services, precious metals, and shell banks.
• Additional documentation, senior management approval, and enhanced transaction monitoring.

7. Sanctions Compliance

Poce Technology maintains a comprehensive sanctions compliance program to ensure we do not engage in transactions prohibited by applicable sanctions laws. We screen all customers, transactions, and counterparties against sanctions lists maintained by:

• Office of Foreign Assets Control (OFAC)
• United Nations Security Council (UNSC)
• European Union Consolidated Sanctions List
• HM Treasury (HMT) Financial Sanctions List
• Other applicable jurisdictional sanctions lists

8. Transaction Monitoring

We employ automated transaction monitoring systems to detect potentially suspicious activity. Our monitoring framework includes:

• Rule-based scenarios designed to detect known money laundering typologies.
• Behavioral analytics to identify deviations from expected customer activity patterns.
• Threshold-based alerts for transactions exceeding specified monetary values.
• Cross-border transaction monitoring for unusual patterns, structuring, or layering.
• Regular tuning and validation of monitoring rules to reduce false positives.

9. Suspicious Activity Reporting

When potentially suspicious activity is identified through our monitoring systems or other means, our compliance team conducts a thorough investigation. If the investigation determines that suspicious activity cannot be ruled out, we file a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) with the appropriate financial intelligence unit. All employees are strictly prohibited from disclosing the existence or content of any SAR/STR filing ("tipping off").

10. Record Keeping

We maintain comprehensive records to demonstrate compliance with AML/CTF requirements. Records are retained for a minimum of five (5) years following the termination of the customer relationship or completion of the transaction, whichever is later. Records include:

• Customer identification and verification documents.
• Transaction records including amounts, currencies, counterparties, and purposes.
• Risk assessments and due diligence reviews.
• Suspicious activity investigations and SAR/STR filings.
• Training records and compliance program documentation.

11. Employee Training

All employees receive mandatory AML/CTF training upon hire and at least annually thereafter. Training is tailored to employee roles and responsibilities and covers:

• AML/CTF legal and regulatory requirements.
• Red flags and money laundering typologies relevant to our business.
• Customer due diligence and enhanced due diligence procedures.
• Suspicious activity identification and reporting obligations.
• Sanctions compliance and screening procedures.

12. Independent Testing

Our AML compliance program is subject to independent testing at least annually to evaluate its effectiveness. Independent testing is conducted by qualified internal audit personnel or external consultants who are not involved in the day-to-day operation of the AML program. Findings and recommendations from independent testing are reported to senior management and the Board of Directors.

13. Policy Administration

This Policy is administered by the AML Compliance Officer and is reviewed at least annually. Violations of this Policy may result in disciplinary action, up to and including termination of employment or business relationship. Any questions or concerns regarding this Policy should be directed to [email protected].