AML/KYC Policy

1. Introduction and Purpose

This Anti-Money Laundering and Know Your Client Policy (hereinafter — the "AML/KYC Policy" or "Policy") sets out the framework adopted by Marginbase (hereinafter — the "Company", "We", "Us", "Our") operating the Marginbase trading platform at marginbase.com, for the prevention and detection of money laundering, terrorist financing, and other financial crimes.

Money laundering is the process of concealing the origins of funds obtained through criminal activity — including fraud, corruption, drug trafficking, terrorism, and other illegal acts — by converting them into assets or transactions that appear legitimate.

Money laundering typically occurs in three stages:

• Placement — criminally derived cash is introduced into the financial system through deposits, monetary instruments, or other means;

• Layering — funds are moved between accounts or institutions to obscure their origin;

• Integration — funds re-enter the economy as apparently legitimate assets or business revenue.

Terrorist financing may not involve criminal proceeds but involves concealing the origin or intended use of funds that will be used for criminal purposes.

The Company is committed to full compliance with applicable AML/CFT legislation, FATF Recommendations, and international best practices. This Policy applies to all Company operations, personnel, and Client relationships.

2. Scope and Application

2.1 This Policy applies to all Clients of the Marginbase platform, all financial transactions processed through the Platform, and all personnel involved in the provision of the Company's services.

2.2 The Company will not knowingly facilitate transactions that involve the proceeds of crime, terrorist financing, or any other unlawful activity. All suspicious activity will be reported to the relevant competent authorities.

2.3 The Company reserves the right to refuse, restrict, suspend, or terminate services to any Client where compliance with this Policy so requires.

2.4 This Policy is reviewed and updated at least annually, or whenever material changes in applicable law or business circumstances require.

3. Definitions

3.1 "Account" means the Client's registered account on the Marginbase Platform.

3.2 "Client" means any individual who has registered or is seeking to register an Account on the Platform for the purpose of conducting trading operations.

3.3 "KYC" means Know Your Client — the process by which the Company verifies the identity of its Clients and assesses the risk they present.

3.4 "CDD" means Customer Due Diligence — the measures taken to verify Client identity and understand the nature of their activity.

3.5 "EDD" means Enhanced Due Diligence — additional verification measures applied to higher-risk Clients.

3.6 "PEP" means Politically Exposed Person — an individual who holds or has held a prominent public position, including their close associates and family members.

3.7 "Suspicious Transaction" means any transaction that raises reasonable grounds to suspect involvement in money laundering, terrorist financing, or other criminal activity.

3.8 "Beneficial Owner" means the natural person(s) who ultimately owns or controls a Client or on whose behalf a transaction is conducted.

3.9 "Source of Funds" means the origin of the funds used by the Client for trading activities on the Platform.

3.10 "Source of Wealth" means the origin of the Client's total assets and net worth.

3.11 "FATF" means the Financial Action Task Force — the international standard-setting body for AML/CFT.

3.12 "CFT" means Combating the Financing of Terrorism.

4. Client Acceptance Policy

4.1 In some countries and territories, the use of fixed-odds trading platforms may be restricted, regulated, or prohibited by applicable law. The Client is solely responsible for ensuring that their use of the Platform complies with the laws of their country of residence and citizenship. The Company accepts no liability for consequences arising from the Client's use of the Platform in a jurisdiction where such use is not permitted. The Company reserves the right to restrict, suspend, or terminate access to the Platform for users in specific jurisdictions at any time, in response to regulatory developments or legal requirements, without prior notice.

4.2 The Company does not open anonymous accounts. All Clients must be identified and verified before being permitted to make Deposits or Withdrawals.

4.3 The Company does not accept Clients who are on international sanctions lists (OFAC, UN, EU, HMT, DFAT, or equivalent), or who are the subject of ongoing criminal investigations or proceedings known to the Company.

4.4 The Company applies a risk-based approach to Client acceptance. Clients are assessed at the time of registration and on an ongoing basis. Higher-risk Clients are subject to Enhanced Due Diligence (EDD).

4.5 The Company reserves the right to decline an application or terminate a Client relationship without providing a reason, where it determines that accepting or continuing the relationship would present unacceptable compliance risk.

5. KYC Verification Procedures

5.1 Standard Verification (CDD)

All Clients are required to complete standard identity verification before making Withdrawals and, in certain cases, before processing Deposits above specified thresholds. The following documents are required as a minimum:

Proof of Identity (one of the following):

• Valid passport (photo page);

• National identity card (front and back);

• Driver's license (front and back).

Proof of Address (one of the following, dated within 3 months):

• Utility bill (electricity, gas, water, internet);

• Bank statement;

• Official government correspondence.

Proof of Payment Method (as applicable):

• Bank card: photograph showing cardholder name, first 6 and last 4 digits, expiration date. Middle digits may be covered;

• E-wallet: screenshot of the deposit transaction showing payment details, date, time, and e-wallet account number, together with a screenshot showing the account holder's name and date of birth;

• Bank transfer: bank statement or confirmation letter confirming account ownership.

5.2 Document Quality Requirements

5.2.1 All submitted documents must be clear, legible, and unobstructed. No edges, corners, or text may be cut off. Glare must not obscure any data fields.

5.2.2 All data on identity documents must be fully readable. The Client's signature may be covered.

5.2.3 Documents must be valid and not expired at the time of submission.

5.2.4 The Company uses automated and manual checks to detect document tampering, Photoshop editing, or other manipulation. Documents found to have been altered will result in immediate Account suspension.

5.2.5 Documents submitted in languages other than English, Portuguese or Spanish must be accompanied by a certified English, Portuguese or Spanish translation, together with a copy of the original document.

5.2.6 Watermarks on document scans are permitted.

5.3 Selfie and Video Verification

5.3.1 The Company may require the Client to submit a selfie photograph holding their identity document clearly visible, with the Client's face fully visible and matching the identity document.

5.3.2 For higher-risk Clients or where doubt exists, the Company may conduct a video verification call via using a platform of the Company's choice.. The Client will be notified at least 24 hours in advance.

5.3.3 The Client must present their original identity document and any payment cards used for Deposits during the video verification session.

5.4 How to Submit Documents

Clients must submit verification documents electronically to:

[email protected]

Accepted file formats: JPG, JPEG, PDF. Documents submitted in RAR, ZIP, DOC, or DOCX format will not be accepted.

Verification is typically completed within 20 minutes of receipt of a complete document set. In complex cases, the Company may extend this period to up to 7 calendar days.

6. Enhanced Due Diligence (EDD)

6.1 Enhanced Due Diligence is applied to Clients who present a higher risk of money laundering or terrorist financing. EDD may be triggered by any of the following:

• The Client is identified as a Politically Exposed Person (PEP) or a close associate or family member of a PEP;

• The Client is a national of or resident in a high-risk jurisdiction as identified by FATF or the Company's internal risk framework;

• The Client's transaction patterns are inconsistent with their stated profile or source of funds;

• Any single transaction or cumulative transactions exceed EUR 5,000 (or equivalent);

• Any other factor that raises concern about the legitimacy of the Client's identity, funds, or activity.

6.2 EDD measures may include one or more of the following:

• Request for documentation evidencing Source of Funds (salary slips, tax returns, sale of property, inheritance, loan agreements, etc.);

• Request for documentation evidencing Source of Wealth;

• Request for a second form of identity document;

• Notarised and/or apostilled copies of identity or address documents;

• Video verification call;

• Ongoing monitoring of transactions at an elevated frequency;

• Senior management approval before proceeding with the Client relationship.

6.3 PEP Screening: All Clients are screened against global PEP, sanctions, and watchlists at onboarding and on an ongoing basis, using AML screening services referencing OFAC, UN, HMT, EU, DFAT, Interpol, and equivalent international databases.

6.4 Where a PEP is identified, the Company will apply EDD, obtain senior management approval, and establish by appropriate means the Source of Wealth and Source of Funds of the Client before proceeding.

7. Ongoing Transaction Monitoring

7.1 The Company monitors all Client transactions on an ongoing basis to detect patterns or activities inconsistent with the Client's known profile.

7.2 The following activities are treated as triggers for enhanced review and potential Suspicious Activity Reporting:

• Any single transaction or Withdrawal exceeding EUR 5,000 (or equivalent);

• Multiple Withdrawals within a single day totalling EUR 5,000 or more;

• A Deposit of EUR 1,000 or more with no subsequent trading activity within 30 calendar days;

• Withdrawals to accounts not belonging to the Client;

• Structured transactions designed to avoid reporting thresholds;

• Rapid cycling of funds through the Account with minimal trading activity;

• Failure to respond to compliance enquiries within 30 calendar days.

7.3 The Company performs annual re-verification of Client identity, and additionally when the Client's identification data changes (including expiry of identity documents).

7.4 The Company has the right to conduct at least one (1) additional identification procedure per year, requiring submission of updated documentation in accordance with this Policy.

8. Suspicious Activity Reporting

8.1 Where the Company's compliance team knows, suspects, or has reasonable grounds to suspect that a Client or transaction is connected to money laundering or terrorist financing, it will file a Suspicious Activity Report (SAR) / Suspicious Transaction Report (STR) with the relevant Financial Intelligence Unit as soon as practicable.

8.2 The Company is prohibited from "tipping off" any Client or third party that a report has been or may be filed. The Client will not be informed that their account or transactions are under review in connection with a potential SAR.

8.3 Where a SAR has been filed or is under consideration, the Company may freeze, restrict, or terminate the Client's Account and withhold funds pending investigation or instructions from competent authorities.

8.4 The Company's counter-measures upon detection of suspicious activity include:

• Cancellation of transactions and blocking of the Account if fraud is detected after funds have been credited;

• Refusal of Withdrawal requests where the Company suspects the Account is being used for exchange transactions between payment systems;

• Immediate Account freeze without prior notice where fraud or deception is suspected;

• Referral of the matter to the relevant Financial Intelligence Unit.

9. Prohibited Activities

The following activities are strictly prohibited on the Marginbase Platform:

• Depositing funds derived from criminal, illegal, or fraudulent activity;

• Using the Platform for the purpose of money laundering or terrorist financing;

• Using the Platform to conduct currency exchange transactions between payment systems;

• Depositing or receiving funds from third parties;

• Operating more than one Account on the Platform;

• Selling, transferring, or purchasing Accounts;

• Managing funds on behalf of third parties through a Client Account;

• Circumventing geo-restrictions through VPNs or other technical means;

• Providing false, misleading, or incomplete information to the Company;

• Attempting to reverse-engineer, exploit, or manipulate the Platform's trading infrastructure.

Violation of any of the above will result in immediate Account suspension, cancellation of pending transactions and Trading Operations, and may be reported to competent authorities.

10. Deposits, Withdrawals, and Source of Funds

10.1 The Client may only deposit funds from payment accounts held in their own name. Third-party deposits are strictly prohibited and will be returned.

10.2 Withdrawals will only be processed to the same account and by the same method used for the corresponding Deposit. If this is technically not possible, the Client must provide an alternative account in their own name that has been verified.

10.3 The Company may request documentation confirming the Source of Funds at any time. Failure to provide such documentation may result in suspension of Withdrawal rights and/or Account closure.

10.4 The Company does not accept cash deposits or payments through anonymous payment systems.

10.5 All payment details provided by the Client must accurately match the verified identity on file. Discrepancies will trigger a compliance review.

10.6 The Company records all deposit and withdrawal transactions and retains these records for the minimum period required by applicable law.

11. Client Obligations

By registering on the Marginbase Platform, the Client undertakes to:

11.1 Provide accurate, complete, and up-to-date personal information at registration and update this information promptly upon any change, including change of address, phone number, or expiry of identity documents.

11.2 Submit all verification documents requested by the Company promptly and in the required format.

11.3 Trade exclusively with their own funds obtained from lawful sources.

11.4 Use the Account exclusively for their own trading purposes and not on behalf of third parties.

11.5 Cooperate fully with the Company's verification, compliance, and investigation procedures, including responding to enquiries within 30 calendar days.

11.6 Notify the Company immediately upon any unauthorised access to their Account or any change in their personal, legal, or financial circumstances that may be relevant to compliance.

11.7 Acknowledge that the Company may record communications with Client Support for quality assurance, compliance, and fraud prevention purposes.

11.8 Acknowledge that the Company may share Client data with competent authorities, regulators, and law enforcement agencies as required by applicable law.

12. Record Keeping

12.1 The Company maintains records of all Client identification documents, transaction histories, correspondence, and compliance decisions for a minimum period as required by applicable law (typically 5 years from the end of the Client relationship or the date of the transaction).

12.2 All records are stored securely and are accessible to authorised compliance personnel and regulators upon request.

12.3 The Company employs third-party compliance technology providers where appropriate, subject to equivalent data protection and confidentiality standards.

13. Staff Training and Compliance Programme

13.1 All employees whose duties involve Client-facing services, payment processing, or compliance functions are required to complete AML/KYC training as part of their onboarding programme.

13.2 Annual refresher training is mandatory for all employees with day-to-day AML and KYC responsibilities.

13.3 The Company maintains an ongoing compliance programme to ensure adherence to applicable laws and regulations, including monitoring of regulatory developments and updates to this Policy.

13.4 The Company may engage independent third-party contractors to carry out Client verification, subject to equivalent standards of data protection and regulatory compliance.

14. Data Protection and Confidentiality

14.1 All personal data collected in the course of KYC and AML procedures is processed in accordance with the Company's Privacy Policy and applicable data protection legislation.

14.2 Client data collected for AML/KYC purposes will not be used for any purpose other than compliance, fraud prevention, and fulfillment of legal obligations.

14.3 The Company may share Client data with: (i) competent regulatory authorities and law enforcement agencies; (ii) Financial Intelligence Units; (iii) licensed third-party identity verification providers; and (iv) group entities, subject to appropriate data protection safeguards.

14.4 The Company will not sell or otherwise commercially exploit Client personal data.

15. Contact Information

For all AML/KYC-related enquiries, document submissions, and compliance matters, Clients should contact:

Compliance & Verification Team — [email protected]

Client Support — [email protected]

This Policy is published on the Platform at marginbase.com and is updated periodically. Clients are responsible for reviewing the current version.

AML/KYC Policy Ver. 1.0 · Marginbase · marginbase.com