AML Policy

BLOCK LABS LTD AML POLICY

Last Updated: December 13th, 2024

Operator: Block Labs LTD Jurisdiction: Belize

Introduction

Block Labs LTD is incorporated in Belize and is committed to preventing money laundering and terrorist financing. This AML Policy outlines our obligations, processes, and controls designed to detect, deter, and report suspicious activities in compliance with the laws and regulations of both Belize and Anjoun, as well as international standards.

Scope

This AML Policy applies to:

• All Block Labs LTD employees, including contractors and agents.

• All customers using Block Labs services.

• All transactions conducted on the Block Labs network, blockchain, and platforms.

Block Labs complies with the regulations set forth by Anjoun’s licensing authorities and adheres to the incorporation laws of Belize. It also observes relevant international frameworks, including but not limited to:

• Applicable AML Regulations in Belize and Anjoun

• Financial Action Task Force (FATF) recommendations

AML Governance and Oversight

Designated AML Compliance Officer (AMLCO)

Block Labs appoints an AML Compliance Officer (AMLCO) responsible for:

• Developing and enforcing AML policies and procedures.

• Overseeing customer due diligence (CDD) and enhanced due diligence (EDD) measures.

• Monitoring transactions and investigating suspicious activities.

• Filing Suspicious Activity Reports (SARs) with regulatory authorities in Anjoun and, if applicable, authorities in Belize.

• Conducting regular AML training for staff.

Customer Due Diligence (CDD)

Ongoing Monitoring

Wallet addresses are subject to monitoring to ensure activities align with their known profile. Any anomalies or high-risk behaviors trigger further investigation.

Transaction Monitoring

Block Labs LTD employs automated and manual transaction monitoring systems to identify potentially suspicious activities, including:

• Large or unusual transactions inconsistent with customer profiles.

• Transactions involving high-risk jurisdictions.

• Patterns indicative of structuring, layering, or other money laundering techniques.

• All flagged transactions are reviewed by the AMLCO and, if necessary, reported to the relevant authorities.

Reporting Obligations

Suspicious Activity Reporting (SAR)

Block Labs complies with legal obligations to file SARs for any activity suspected of involving money laundering or terrorist financing. SARs are filed with the appropriate Financial Intelligence Unit (FIU) or equivalent authority.

Employee Training

All employees undergo mandatory AML training upon hire and on an annual basis thereafter. Training topics include:

• Recognizing money laundering and terrorist financing indicators.

• Understanding KYC and CDD procedures.

• Filing SARs and maintaining confidentiality.

Risk Assessment

Block Labs conducts periodic risk assessments to evaluate the effectiveness of its AML measures. The assessment includes:

• Identifying potential AML risks associated with customers, geographies, and products.

• Reviewing and updating policies to address emerging threats.

Prohibited Activities

Block Labs strictly prohibits the following:

• Transactions with individuals or entities on sanctions lists (e.g., OFAC, UN, EU).

Consequences for Non-Compliance

Non-compliance with this AML Policy by employees or customers will result in:

• Disciplinary action or termination of employment for employees.

• Reporting violations to regulatory authorities, if applicable.

Policy Review

This AML Policy is reviewed and updated annually, or as required by changes in regulations in Belize, Anjoun, or internationally, to ensure its effectiveness and relevance.

Block Labs LTD

Incorporated in: Belize

Contact Information: [e-mail]