ADN BROKER, is a private company (hereafter referred to by its trading name, « ADN BROKER »). In our interest to ensure the protection of all our clients against crimes related with money-laundering or any other financial crime, promoting legal and transparent trade in our website. Our company has prepared this KYC & AML Policy in order to summit our voluntary compliance to national and international AML standards.

This KYC & AML Policy is part to and incorporated to our Terms and Conditions and our Privacy Policy and they will be applied to any user of the website www.adnbroker.com By using the website, you are consenting to our terms and conditions and to this policy regardless if you already have an account or if you are looking to have an account with us. If your use of this website is attempting to commit any criminal activity, you must stop using our services and/or the website.

In order to comply national or international laws, we have the right, at any time, to change or modify the terms of this KYC & AML Policy, or to impose new conditions, including, but not limited to, adding fees and charges for use. Such changes, additions or deletions shall be effective immediately upon notice thereof. For the purposes of relevant changes of this policy, the Chief Officer in charge of AML can be reached at: accounts@adnbroker.com.

Risk Assessment: For Risk Assessment, we may categorize you as a low-risk, medium-risk, or a high-risk user on the following basis:

Sufficiency and adequacy of identification documents submitted by user;

Social and/or financial status of user;

Nature and other similar information about your business/vocational activities; or

Guidance notes circulated by various governmental and inter- governmental organizations.

Your risk categorization will always be confidential, subject to any requests received from a competent law enforcement authority. The risk assessment will not be disclosed to any user under any circumstances.

Know your Customer: Users may be required to take part in the user identification a verification process at the time of registration, and further on periodically for purposes of updating records and on-going due-diligence. For this purpose, we will follow the procedure established under this Clause.

Individual Users: For verification of identification purposes, we will require from individual users: Name; date of birth; email address; phone number and residential address; photograph; copies or certified copy of any Valid Documents to prove identification; and documents pertaining to business/financial status of such use.

Business Users: name, contact-details, copy of Valid Documents of the authorized representative, one certified copy each of the certificate of incorporation/registration certificate; board resolution/other authorization documents giving authority to the representative chosen to execute the transactions that will be done at the website.

Individual and business users should update us of any changes to the customer information provided to us within three days of effecting such changes. You must file a fresh proof of address within three (3) months of effecting any changes to the address mentioned as per the ‘proof of address’ submitted by you.

Procedure for Identity Verification: We may require you other information or documents as may be deemed necessary to verify your identity, if we cannot verify your identity or if we have a reason to believe that you are a person or entity whose details are provided in any official, governmental or intergovernmental sanction list regarding the AML efforts. ADN BROKER reserves the right to refuse registration to anyone that doesn’t fit our policy.

We may also require you to certify that your Linked Bank Account is held only with a scheduled commercial bank which is compliant with all Know Your Customer procedures mandated under the applicable laws. For this purpose, we may require you to furnish this certification in such format as may be prescribed by us.

ADN BROKER reserves the right to refuse registration to, or to bar transactions from or to, or terminate any relationship with, any customer for any reason (or for no reason) at any time. This includes, but is not limited to, anyone from or in jurisdictions that do not meet international AML standards as set out by the Financial Action Task Force on Money Laundering; anyone on an official, governmental or intergovernmental Sanction Lists; upon reasonable request or direction of a competent enforcement authority; or, anyone that fails to meet any customer due diligence standards, requests, or requirements of ADN BROKER.

If we believe any information obtained from the user hereunder is (a) inadequate or incomplete; (b) false or misleading; (c) insufficient resulting in an inability to readily verify the same; or (d) appearing on any Sanctions Lists, we may in our sole discretion either refuse or terminate (as the case may be) the registration of such Account or require such user to verify the Valid Documents submitted by it again. We may also, in our sole discretion, refuse to open any new accounts, terminate existing User Accounts after giving due notice, or refuse to process any transactions on the Website if we are unable to verify any information due to non-cooperation by the user, or if such transactions are likely to have an material adverse effect on us for being in violation of any applicable laws or industry best-practice guidelines.

Third-party assistance: We may request one or more appropriate third-party service provider to assist us in authentication and verification of the Valid

Documents and other incidental details provided by you. In addition to the above, we reserve the right to verify customer identity through non-documentary means or both. We may also use non-documentary means if we are still uncertain about whether we know the true identity of a User. We will use the following non-documentary methods of verifying identity:

1. a) Confirming validity of email;
2. b) Confirming validity of telephone number, bank account number; and
3. c) Confirming your location using, among others, your IP address; all of which may be carried out by an automated or manual process.

Activity Monitoring We may monitor and flag for review all transactions where the amounts involved exceed limits specified by local or applicable laws, official guidelines, or industry best practices. In addition to the above, we may regularly monitor, through both manual screening and use of software-based algorithms, all transactions executed and/or attempted to be executed on our Website, in order to promptly identify and highlight any suspicious activity, which includes without limitation, activities that appear:

To collection of funds to be used, either in full or in part, by any criminal organization, or in order to carry out any of the activities relating to terrorism, or terrorist acts;

to have been structured in a manner of unusual or unjustified complexity in order to avoid triggering any reporting requirements;

to have been transacted for a mala fide purpose or where a sound economic rationale cannot be

to signal possible ‘money-laundering’ activities, as defined under applicable laws.

to be unusual due to the reason of being inconsistent with any User’s risk profile, expected usage pattern or sophistication. The extent of monitoring shall depend on various factors including upon each User’s risk.

On detection of any suspicious activity, we reserve the right to take appropriate actions without any prior notification to the User, which includes, without limitation,

(i)terminating the Account, (ii) restricting and/or blocking further access to our Website, and (iii) notifying the appropriate enforcement authorities regarding the suspicious activities of any User.

ADN BROKER will maintain records as follows:

Records of all transactions executed by you on our Website, for a period of at least 5 (Five) years from the date of each of them;

Records of all suspicious transactions or trans-national transactions, for a period of at least 10 (Ten) years, including but not limited to the information about the nature and value of the transactions, parties involved in such transactions, and information about the date of remittance;

Identification records of Users for a period of at least 5 (Five) years from the

date of termination of such user.

Notifications between the parties In order to ensure compliance with this KYC & AML Policy and/or the applicable laws, the Company may be required to send you notices from time to time. All such notices will be sent to such address as provided by you. Where you are required to share any information according to the procedures contained in this KYC & AML Policy, such communication may be made by you electronically by sending an email to our Chi