AML Policy

Introduction

This AML Policy applies to all branches and subsidiaries of GLOBALLY UNITED TECH CORPORATION (Company). The Company incorporated in Vancouver, Canada, with the company number BC1482082.

Address of the Company: 142 757 West Hastings Street PMB 818 Vancouver BC V6C 1A1 Canada.

The Company maintains full cooperation with law and regulatory authorities in legislations, investigations, and inquiries in Canada and abroad.

The Company adopts appropriate, sufficient measures aimed to prevent its operations from being used as means to conceal, manage, invest, or use any form of money – or other assets – due to illicit activities, or to give the appearance of legality to such activities.

What is Money Laundering

The term "money laundering" (ML) means any act or attempted act to disguise the source of money or assets derived from criminal activity.

What is Terrorist Financing

The term "terrorist financing" (TF) means an offence committed by any person who by any means, directly or indirectly, unlawfully and willfully, provides or collects funds with the intention that they should be used or in the knowledge that they are to be used, to cause death or serious bodily injury to a civilian, or to any other person not taking an active part in the hostilities in a situation of armed conflict. When the purpose of such an act, by its nature or context, is to intimidate a population, or to compel a government or an international organization to do or to abstain from doing any act.

Prohibited activities

The Company has the list of prohibited activities, which includes:

• Prohibition of anonymous accounts: Opening anonymous accounts is prohibited if there is a reasonable suspicion that the data recorded in these documents is fake or falsified.
• Prohibition of shell banks: The Company does not maintain business relationships with shell banks, which is defined as a financial institution incorporated in a jurisdiction in which it has no physical presence.

If prohibited risk activity is identified in the course of the business relationship established – such relationship shall be terminated in accordance with this Policy.

Also the Company does not onboard customers that provide Restricted activities:

• Drugs and drug paraphernalia (e.g., narcotics, controlled substances, and any equipment designed for making or using drugs);
• Marijuana/cannabis dispensaries and related products and businesses;
• Weapons, munitions, gunpowder, and other explosives (including fireworks);
• Toxic, flammable, and radioactive materials;
• Pseudo-pharmaceuticals, Substances designed to mimic illegal drugs;
• Sexually explicit content, Sexually-related services;
• Pyramid and investment schemes, multi-level marketing schemes, and other unfair, predatory or deceptive practices;
• Items used for speculation or hedging purposes (such as derivatives);
• Sale or supply of goods through dark web markets;
• Credit and collection services;
• Charity and other not for profit organisations;
• Financial institutions that allow for unlimited Wallets;
• Financial services that allow for anonymous exchanges or other anonymous services;
• Sale or supply of oil;
• Sale, supply or manufacturing of precious metals and stones;
• Sale, supply or manufacturing of tobacco based products;
• Sale or supply of cultural artefacts;
• Sale of supply of goods related to protected species;
• Financial institutions that allow for exchange of privacy coins;
• Mixer/Tumbler services;
• Any Illegal goods or paraphernalia that may be used for illegal activity;
• Art dealerships;
• Sale of supply of unlicensed pharmaceuticals;
• Items that infringe or violate any intellectual property rights such as copyrights, trademarks, trade secrets, or patents, including counterfeit or unauthorized goods;
• Products and services with varying legal status from state to state;
• Transactions that disclose the personal information of third parties in violation of applicable law;
• Transactions related to cloud-mining;
• Transactions involving sanctioned entities;
• Any other business activity which, in our sole discretion, is outside our risk appetite.

The usage of the Company’s services is prohibited for citizens and/or residents of the following countries (territories) and jurisdictions: Afghanistan, American Samoa, U.S. Virgin Islands, Territory of Guam, Iran, Yemen, Libya, State of Palestine, Puerto Rico, Somalia, the Democratic People's Republic of Korea, The Northern Mariana Islands, Syria, Russian Federation, Republic of Belarus, Republic of Sudan, Transnistria, temporarily occupied territories of Georgia, Turkish Republic of Northern Cyprus, Western Sahara, Federal Republic of Ambazonia, Kosovo, South Sudan, Nicaragua, Trinidad and Tobago, Venezuela, Myanmar, and temporarily occupied territories of Ukraine.

Customer due diligence

Customer due diligence (CDD) is central to an effective AML/CTF regime. The Company applies the following CDD measures:

• Identification of the customer and verification of the customer’s identity;
• Identification and taking reasonable measures to verify the beneficial owner’s identity;
• Identification and taking reasonable measures to verify if the customer is a PEP/HIO or a person connected to PEP/HIO (family members, close associates, etc.);
• Obtaining an information on the purpose and intended nature of the business relationship or transaction, unless the purpose and intended nature are obvious;
• Apply Enhanced Due Diligence (EDD) for high-risk customers and customers from high-risk jurisdictions;
• Monitoring of the business relationship.

Where Company doesn't have relevant CDD data of customer, it won't establish a business relationship or won't carry out any occasional transaction with that customer or will terminate business relationship as soon as reasonably practicable, and where there is relevant knowledge or suspicion, will send the relevant report to the FINTRAC.

Keeping customer information up to date

The Company takes steps from time to time to ensure that the customer information that has been obtained is up-to-date and relevant. To achieve this, the Company undertakes periodic reviews of existing records of customers.

Know Your Customer

Identification of the customer - natural person

The use of personal information in Canadian commercial activities is protected by the Personal Information Protection and Electronic Documents Act (PIPEDA), or by similar provincial legislation. The Company informs the customers about the collection of their personal information, except for cases when the Company includes their personal information in the reports required to be submitted to FINTRAC.

In the course of customer’s onboarding procedure, the Company shall identify the customer and verify the identity of the customer who is a natural person and, where relevant, their representative by using any of the methods specified below and referring to these documents, data or information provided by a reliable and independent source that is required for each specific method.

The Company can use services of third-party providers for documents verification, facial recognition and sanction screening etc. If the Company uses third-party service, it is done on the contractual basis with application of GDPR requirements.

During the process of verification, the following data shall be collected and retained for the identification and verification of the customer:

• Person's name, date of birth, place of birth;
• Photograph (or live video, can be made with the help of third-party providers);
• Date of verification;
• Type of document;
• Unique identifying number of the document used;
• Place of issue and expiry date (if available).

The Company identify the customer and verify the identity of the customer by referring to these documents, data or information provided by a reliable and independent source that is required, but not limited to:

• An identity document (passport, international passport, ID card etc.) or permanent resident card issued by the government of the relevant country;
• An identity document issued by a foreign government if it is equivalent to an identity document;
• Driver's license.

In addition, the aforementioned documents must meet all the requirements in order to use them for the identification of a natural person. The document must:

• Be authentic, current and valid;
• Be issued by an official government;
• Indicate the person's name;
• Include a photo of the person;
• Include a unique identifying number (if applicable); and
• Match the name and appearance of the person being identified.

To confirm their place of residence, the client provides a utility bill, bank statement, or government-issued document. This document may be requested by the Company. The Company may also verify the client's source of wealth or the origin of their funds (source of funds). The documents required depend on the client's specific situation, e.g. payroll statements, real estate purchase agreements, and certificates of inheritance etc.

Identification of the customer – legal entity

The Company identifies the customer and verifies the identity of the customer, who is a legal entity and their representative. The following data shall be collected and retained for the identification and verification of the customer includes:

• Business name;
• Business address;
• Registration number;
• Paper record or an electronic version of a record or their copies.

The following documents which contain data specified for the confirmation of existence method may be used as the basis for the identification of a legal person (entity), but not limited to:

• Partnership agreement;
• Certificate of incorporation;
• Extract from the registry;
• Articles of association;
• The most recent version of any other record that confirms its existence and contains its name and address (incl., record from a publicly accessible database).

The records must be authentic, valid and current.

The client is supposed to provide the document that proves the address, who is the director, who is the ultimate beneficial owner, and provide information about the company's owners who hold 25% or more of the shares. Additionally, the type of business, website (if applicable), and license (if required) are also required for client assessment. If the Company requests these documents, please provide them. The company also verifies the client's beneficial owners and requires the copy of identity document and proof of address.

The identification of the customer's Beneficial Owner

The beneficial owner means any natural person who owns the customer (a legal person or a foreign undertaking) or controls the customer and/or the natural person on whose behalf a transaction or activity is being conducted.

The Company identifies the beneficial owner of the customer and takes measures to verify the identity of the beneficial owner to the extent that allows the Company to make sure that they know who the beneficial owner is. The Company collects the following data regarding the customer's beneficial owner(s):

• Name(s) and surname(s);
• Address(es);
• Information about the ownership, control and structure of the entity.

The Company shall request from the customer information about the customer's beneficial owner and supporting official documentation (e. g. providing the customer with an opportunity to specify their beneficial owner when collecting data about the customer), conduct an open-source search or consult publicly available information.

If the Company is unable to obtain the beneficial ownership information, the legal entity cannot be onboarded.

Identification of the purpose and nature of the business relationship or a transaction

The Company shall understand the purpose and nature of the establishing Business Relationship or performing transaction. Depending on the Company risk assessment of the situation, measures required may include:

• The customer confirming that the Company’s terms of services provision are accepted;
• The customer providing additional information in regards of transaction(s) performed (e. g. in the course of EDD measures or monitoring of the business relationship as specified below).

The Company shall apply additional measures and collect additional information to identify the purpose and nature of the Business Relationship or an Occasional Transaction in cases where:

• There is a situation that refers to high value or is unusual;
• Where the risk and/or risk profile associated with the customer and the nature of the business relationship gives reason for the performance of additional actions in order to be able to appropriately monitor to business relationship later (e. g. if the customer is residing or established in high-risk third countries).

Enhanced due diligence measures

The Company applies Enhanced Due Diligence (EDD) measures where the customer and product/service combination is considered to be a greater risk. This higher level of due diligence is required to mitigate the increased risk. A high-risk situation generally occurs where there is an increased opportunity from money laundering or terrorist financing through the service and product the Company provides or from a customer of the Company.

What the EDD actually entails will be dependent on the nature and severity of the ML/TF risk.

To conduct EDD, the Company requires the client to provide additional information and documents. Please provide all required documents. If the documents are not provided, or if they are inaccurate or fake, the Company will not be able to onboard the client and/or allow them to use the services and conduct transactions.

Politically Exposed Person's / Head of International Organization's

Politically exposed person (PEP) means a natural person who holds or has held:

• A specific office or position in or on behalf of the Canadian federal government, a Canadian provincial (or territorial) government, or a Canadian municipal government within the last 5 years (domestic PEP);
• An office or position in or on behalf of a foreign state (foreign PEP).

Head of international organization (HIO) means the natural person who currently holds or has held within the last 5 years the specific office or position of head of an international organization and the international organization, including:

• International organization established by the governments of states;
• Institution of an organization referred above;
• International sports organization.

Close Family Member means the spouse or common-law partner, biological or adoptive child(ren), mother(s) and father(s) and their spouse or partner, brother(s) and sister(s) of a PEP/HIO.

Close Associate is a natural person who:

• Is a business partner of, or who beneficially owns or controls a business with, a PEP/HIO;
• Is in a romantic relationship with PEP/HIO;
• Is involved in financial transactions with a PEP/HIO;
• Serves as a member of the same political party or board as a PEP/HIO;
• Carries out charitable works with a PEP/HIO;
• Is listed as joint on a policy where one of the holders might be a PEP/HIO.

The Company takes measures to ascertain whether the customer, the beneficial owner of the customer or the representative of the customer is a PEP, their family member or close associate or if the customer has become such a person.

The risk appetite of the Company states that the Company treats all the ex-PEPs and close associates like PEPs, applying the principle "Once a PEP - always a PEP". The company is reluctant to onboard PEPs (or legal entities with UBOs - PEPs or close associates) because it considers it beyond its risk appetite. However, if the company deems it necessary and beneficial to onboard such a client, then this can happen with the approval of the company's senior management.

The identification of Third Party

Third party is the person or entity that instructs the customer to conduct a transaction or activity on their behalf. The company must identify the third party using the same KYC procedures, depending on the type of third party (legal entity or natural person).

Ongoing monitoring

The Company monitors the transactions concluded during the business relationship. The Company monitors the business relationship to ascertain the customer’s activities or facts that indicate criminal activities, ML/TF or the relation of which to ML/TF is probable, incl. complicated, high-value and unusual transactions and transaction patterns that do not have any reasonable or obvious economic or legitimate purpose or that are uncharacteristic of the specific features of the business in question. The company may request documents related to the client's income or activities for the purpose of such monitoring. If the client refuses to provide documents, their account may be closed and the relationship with the client terminated.

Transaction monitoring

The Company uses transaction monitoring tools to detect and analyse potentially suspicious activities. These tools perpetually monitor transactions, account behavior, and patterns that may be indicative of ML/TF. In the event that suspicious activity is identified, the Company will report it to the FINTRAC in adherence to the laws of Canada.

If a transaction is alerted by the transaction monitoring system, it is stopped for additional verification. The Company may request additional documentation regarding the client, transaction, or counterparty. After verification, the transaction may be approved, blocked for re-checking, or rejected.

Reporting

The Company detects any suspicious activities and ML/TF indicators. The detection of such activities and indicators are subject to reporting obligation to appropriate regulatory and law enforcement authorities.

Sanctions policies

This Policy also covers the Company’s obligations related to implementation of sanctions legally binding to the Company. The Company follows the Guidance, issued by FINTRAC and FATF and takes measures to ensure compliance with the relevant regulations and legislation on sanctions in Canada. The Company takes into account the following sanction regimes:

• Canadian Sanctions (incl., UNA, SEMA and JVCFOA);
• UN Sanctions;
• OFAC Sanctions.

Data retention

The Company implements all rules of protection of personal data upon the requirements arising from the applicable legislation. The Company is allowed to process personal data gathered upon CDD measures implementation only for the purpose of preventing money laundering and terrorist financing and the data must not be additionally processed in a manner that does not meet the purpose.

Record keeping

The data and documents retain for at least 5 years according to Canadian law. The time limits for record keeping may be extended additionally under the instruction of a competent authority.

Training of team members

The Company ensures that its employees have the relevant qualifications for their work tasks. In accordance with the requirements applicable to the Company, it makes sure that such employees receive appropriate training and information on an ongoing basis to be able to fulfil the Company’s obligations.

Periodic review

This Policy undergoes periodic review by the Company to ensure its effectiveness and compliance with regulations and best practices. The effective date signifies the commencement of the latest version of this policy. Any changes to the effective date will be clearly indicated at the beginning of this document.