MoneyBlink Anti-Money Laundering & Counter-

Terrorist Financing (AML/CFT) Policy

Introduction

MoneyBlink, as a licensed Electronic Money Institution (EMI) regulated by the Malta Financial Services Authority (MFSA), is committed to the highest standards of financial integrity. Our mission is to prevent our platform from being used for money laundering (ML) or the funding of terrorism (FT). This policy outlines the framework designed to detect, assess, and mitigate financial crime risks.

Regulatory Framework

MoneyBlink operates in strict accordance with:

• The Prevention of Money Laundering Act (PMLA) (Cap. 373 of the Laws of Malta).

• The Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR).

• The Implementing Procedures issued by the Financial Intelligence Analysis Unit (FIAU).

• The 6th and 7th EU AML Directives (as transposed into Maltese law).

Risk-Based Approach (RBA)

We do not apply a "one-size-fits-all" model. MoneyBlink employs a Risk-Based Approach to identify high-risk customers, jurisdictions, and transaction patterns. Our risk assessment considers:

• Customer risk (e.g., Politically Exposed Persons - PEPs).

• Product/Service risk (e.g., high-velocity e-money transfers).

• Geographical risk (e.g., FATF non-cooperative jurisdictions).

Customer Due Diligence (CDD) & KYC

Before establishing a business relationship, MoneyBlink performs rigorous "Know Your Customer" (KYC) and "Know Your Business" (KYB) checks:

1. Identification and Verification: Collection of government-issued IDs and proof of address, verified via biometric liveness checks.

2. Beneficial Ownership: For corporate clients, we identify and verify the Ultimate Beneficial Owners (UBOs) holding 25% or more interest.

3. Nature of Business: Understanding the source of funds (SoF) and source of wealth (SoW).

Enhanced Due Diligence (EDD)

Where a high risk is identified, MoneyBlink applies EDD measures, including:

• Obtaining additional information on the customer and the intended nature of the business relationship.

• Senior management approval for onboarding PEPs or high-risk entities.

• Stricter ongoing monitoring of transactions.

Sanctions Screening & Transaction Monitoring

MoneyBlink utilizes automated, real-time screening against global sanction lists (UN, EU, OFAC, UK HMT).

• Transaction Monitoring: Our AI-driven systems monitor account activity for unusual patterns (e.g., structured deposits, rapid cross-border transfers to high-risk zones).

• Prohibited Entities: We maintain a zero-tolerance policy for Shell Banks or customers involved in prohibited industries (e.g., unlicensed gambling).

Reporting Obligations & MLRO

MoneyBlink has appointed a Money Laundering Reporting Officer (MLRO). If any transaction is suspected to be linked to ML/FT, a Suspicious Activity Report (SAR) is filed with the FIAU. Under the "anti-tipping-off" rule, customers will not be informed of such reports.

Record Keeping & Training

In compliance with Maltese law, all CDD and transaction records are retained for a minimum

of five (5) years after the termination of the business relationship. All staff undergo mandatory annual AML/CFT training to stay updated on emerging typologies.