### KYC/AML Policy

*Company Name*: Ziggurah  

*ID Number*: 067178733  

*Date of Establishment*: November 15, 2023  

*Location*: Wyoming, USA  

*MSB License Number*: 31000273780337  

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#### 1. *Introduction*

Ziggurah is committed to complying with all applicable regulations and laws to prevent money laundering, terrorist financing, and other illegal activities. This KYC/AML Policy outlines the procedures and controls we implement to ensure compliance and maintain the integrity of our platform.

#### 2. *Know Your Customer (KYC)*

2.1 *Customer Identification*:

- All customers must provide valid identification documents during the registration process.

- Acceptable identification includes government-issued ID, passport, or driver’s license.

- Customers must also provide proof of address, such as utility bills or bank statements, not older than three months.

2.2 *Verification Process*:

- Identification documents are verified using automated and manual methods to ensure authenticity.

- Enhanced due diligence (EDD) is conducted for high-risk customers, including additional verification and background checks.

2.3 *Ongoing Monitoring*:

- Continuous monitoring of customer transactions to detect suspicious activities.

- Regular reviews of customer profiles and updates of KYC information as necessary.

#### 3. *Anti-Money Laundering (AML)*

3.1 *Risk Assessment*:

- Conduct a risk assessment to identify and evaluate the money laundering and terrorist financing risks associated with our services.

- Implement risk-based controls and procedures to mitigate identified risks.

3.2 *Transaction Monitoring*:

- Monitor transactions for unusual or suspicious patterns that may indicate money laundering or terrorist financing.

- Implement automated systems to flag suspicious transactions for further review.

3.3 *Reporting*:

- Suspicious Activity Reports (SARs) are filed with relevant authorities when suspicious activities are detected.

- Maintain records of all SARs and other AML-related documents for a minimum of five years.

#### 4. *Customer Due Diligence (CDD)*

4.1 *Standard Due Diligence*:

- Apply standard due diligence measures to all customers, including identity verification and risk assessment.

- Ensure that the level of due diligence is proportionate to the customer's risk profile.

4.2 *Enhanced Due Diligence (EDD)*:

- Apply EDD measures to high-risk customers, including politically exposed persons (PEPs), high-value transactions, and customers from high-risk jurisdictions.

- EDD measures may include additional identification requirements, source of funds verification, and ongoing monitoring.

#### 5. *Training and Awareness*

5.1 *Employee Training*:

- Provide regular training to employees on AML/KYC regulations, red flags for suspicious activities, and reporting procedures.

- Ensure employees understand their responsibilities and the importance of compliance with AML/KYC policies.

5.2 *Awareness Programs*:

- Promote awareness of AML/KYC policies and procedures among customers and partners.

- Provide educational materials and resources to help customers understand the importance of AML/KYC compliance.

#### 6. *Record Keeping*

6.1 *Documentation*:

- Maintain comprehensive records of all customer identification, verification, and transaction monitoring activities.

- Ensure records are securely stored and accessible for regulatory audits and reviews.

6.2 *Retention Period*:

- Retain all AML/KYC-related documents for a minimum of five years from the date of transaction or account closure.

- Ensure records are disposed of securely after the retention period.

#### 7. *Compliance and Governance*

7.1 *Compliance Officer*:

- Appoint a dedicated Compliance Officer responsible for overseeing AML/KYC compliance and reporting.

- The Compliance Officer will ensure policies are implemented effectively and updated as necessary.

7.2 *Internal Audits*:

- Conduct regular internal audits to assess the effectiveness of AML/KYC controls and identify areas for improvement.

- Ensure findings are documented and corrective actions are implemented promptly.

#### 8. *Contact Information*

- For any questions or concerns regarding our KYC/AML Policy, please contact us at admin@fxeet.com.

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*Effective Date*: 04/01/2024

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This KYC/AML Policy demonstrates Ziggurah's commitment to preventing money laundering, terrorist financing, and ensuring regulatory compliance through robust identification, monitoring, and reporting procedures.