Anti-Money Laundering (AML) Compliance Program Policy

1. Company Policy

B2Proxy is committed to maintaining the highest standards of Anti-Money Laundering (AML) compliance and preventing any activities that may facilitate money laundering, terrorist financing, or criminal activities. We strictly adhere to all applicable requirements under the Bank Secrecy Act (BSA) and its implementing regulations. Our AML policies, procedures, and internal controls are carefully designed to ensure compliance with all relevant BSA regulations and FINRA rules. B2Proxy will conduct regular reviews and updates to adapt to changes in regulations.

2. Provision of AML Information to Federal Law Enforcement Agencies

B2Proxy is committed to not disclosing information shared with us by FinCEN unless necessary to comply with information requests. The receipt of National Security Letters (NSLs) will be handled with the utmost confidentiality. If we file a Suspicious Activity Report (SAR) after receiving an NSL, the SAR will not contain any information related to the NSL itself and will focus solely on providing detailed information regarding the detected suspicious activity.

3. Monitoring of Accounts for Suspicious Activity

B2Proxy will conduct continuous monitoring of account activity to identify unusual transaction sizes, frequencies, patterns, and types, and will carry out monitoring efforts in conjunction with risk factors and risk signals appropriate to our business.

3.1 Red Signals:

• The identification documents provided by the customer are difficult to verify or are inconsistent or contradictory with other information.

• The customer hesitates, delays, or refuses to provide required complete customer due diligence information, including but not limited to the nature and purpose of the business, past financial relationships, expected account activity, place of business, and, where applicable, information on management and directors.

• The customer is unable to explain the legitimate source of funds or provides false, misleading, or materially inaccurate information.

• The customer’s place of registration, place of business, or principal place of transaction is located in a high-risk jurisdiction known for bank secrecy, tax evasion characteristics, drug production, weak anti-money laundering and counter-terrorist financing systems, or regional conflict.

• The customer is unable to clearly explain the nature of their business or lacks basic knowledge and understanding of their industry.

• The customer has no reasonable or clear commercial reason for using our services or selecting our service channels.

• The customer has previously been refused establishment of a business relationship or had their cooperation terminated by other financial institutions.

• The customer’s legal address or correspondence address is associated with multiple unrelated accounts or businesses.

• The customer conducts business through an agent but fails to disclose the principal and refuses to provide information on the beneficial owner.

• For entities such as trusts, shell companies, or private investment companies, the customer refuses to disclose the controlling entity and ultimate beneficial owner information.

• The customer is involved in known criminal, civil, or regulatory proceedings, including crimes, corruption, misuse of public funds, or is associated with individuals having such backgrounds.

• The customer’s background is questionable, or their business activities are inconsistent with expectations.

• The customer opens multiple accounts or opens accounts in the name of family members or corporate entities without a clear, legitimate business or reasonable purpose.

3.2 Other Potential Red Flags:

• The customer refuses or is unwilling to provide relevant information required for transaction reporting.

• The customer attempts to persuade or obstruct employees from filing statutory reports or maintaining required records.

• The customer shows unusual concern or questions regarding the company’s compliance with government reporting requirements and anti-money laundering policies.

• The relevant transactions lack a clear and reasonable business rationale, operating philosophy, or legitimate investment strategy.

• The customer demonstrates complete disregard for transaction costs, handling fees, and related expenses during the transaction process.

• Securities transactions are cancelled, reversed, or rolled back before maturity without reasonable commercial justification.

• The customer claims to conduct transactions on behalf of a third party but is unable to provide a reasonable and legitimate business basis.

4. Anti-Money Laundering Recordkeeping

The responsibility for retaining necessary anti-money laundering records and filing Suspicious Activity Reports (SARs) shall be borne by the AML compliance officer designated by the institution and their authorized team members. Relevant personnel shall ensure that AML records are accurate, complete, and securely maintained, and that Suspicious Activity Reports are filed in a timely manner in accordance with regulations.

5. Senior Manager Approval

The senior management of B2Proxy has provided formal written approval of this Anti-Money Laundering Compliance Program, confirming that the Program meets the company’s operational management needs. We remain committed to upholding the highest standards of anti-money laundering compliance and actively preventing any illegal or improper activities that may compromise the integrity of the financial system.