Anti-Money Laundering Policy

Introduction

This Anti-Money Laundering (AML) Policy is established to ensure that ThinkCapital complies with all applicable laws and regulations related to anti-money laundering, counter-terrorism financing, and sanctions. This Policy outlines the company’s commitment to preventing money laundering activities and sets guidelines for employees, contractors, and other relevant parties to follow.

Objective

The primary objective of this Policy is to detect, prevent, and report any suspicious activities related to money laundering, terrorism financing, or any other illicit financial activities. ThinkCapital is dedicated to maintaining the integrity of the financial system and ensuring its services are not misused for unlawful purposes.

Scope

This Policy applies to all employees, contractors, and third parties acting on behalf of ThinkCapital. The standards outlined here are the minimum requirements based on applicable legal and regulatory requirements.

Money Laundering

Money laundering involves participating in transactions aimed at concealing or disguising the nature or origin of funds obtained from illegal activities, such as fraud, corruption, organized crime, or terrorism. Predicate offenses for money laundering are determined by local law. The money laundering process typically includes the following stages:

a) Placement: Illegally obtained funds are introduced into financial or non-financial institutions;

b) Layering: Proceeds of criminal activities are separated from their source through complex financial transactions to obscure the origin of funds;

c) Integration: Laundered proceeds are reintroduced into the economy, reentering the financial system as seemingly legitimate funds.

These stages are not static and can overlap. Financial institutions or non-financial institutions can be exploited at any point in the money laundering process.

Client Identification and Verification

ThinkCapital collects and verifies the personal identification data of our account holders, while logging and tracking itemized statements of all the transactions that are carried out by our clients. Prior to opening an account with ThinkCapital, a valid form of government-issued identification (Driver’s License, State ID, or Passport), a proof of address, along with your completed account

application (Know Your Customer). Additionally, ThinkCapital tracks all suspicious transactions of our clients, and transactions executed under non-standard trading conditions.

• ThinkCapital does not under any circumstance allow third-party payments. Transactions are closely monitored and ThinkCapital will reject any attempt of a third-party payment. ThinkCapital performs its actions on the basis of the anti-money laundering framework in accordance with relevant rules and regulations.

• ThinkCapital neither accepts cash deposits nor disburses cash under any circumstances.

• ThinkCapital does not accept third-party payments of any kind.

• ThinkCapital matches each payment to the account name on file for that customer.

• ThinkCapital reserves the right to refuse processing a transaction at any stage where it believes the transaction to be connected in any way to money laundering or criminal activity. In accordance with international law, ThinkCapital is not obligated to inform the client if suspicious activity is reported to any corresponding regulatory or legal bodies.

  ThinkCapital will also continuously monitor and adhere to the latest sanctions lists to ensure compliance with sanctions imposed by relevant authorities.

  Payout Procedures

  The payout process below is structured around strict guidelines to ensure funds are sent securely and in best industry practice. ThinkCapital clients must complete a signed paper or digital payout request containing their correct account information.

• The payout form is submitted to the appropriate department for processing. The compliance department confirms the account balance, verifies that there are no holds or withdrawal restrictions on the account, and then approves the withdrawal request, pending approval by the accounting team.

• ThinkCapital reviews all payout requests approved by the compliance and/or risk department.

• Payout requests approved by ThinkCapital are sent back to the accounting department, and the funds are released to the client.

• In the event that a payout is flagged for suspicious activity, the payout is placed on hold, pending further investigation by ThinkCapital compliance staff, and if necessary, escalated to senior management.

• ThinkCapital frequently analyses whether violations require further action and which, if any, relevant regulatory bodies need to be contacted.

  Compliance Summary

  The compliance procedures listed above are only brief synopsis of the high-level guidelines observed by ThinkCapital.

This AML Policy will be reviewed and updated regularly to reflect changes in regulations, industry best practices, and the evolving landscape of AML and sanctions compliance. All employees and relevant parties are responsible for upholding this Policy and complying with AML laws.