Anti-Money Laundering (AML) Policy for Just Access

Introduction This Anti-Money Laundering (AML) Policy outlines the procedures and safeguards that Just Access implements to prevent money laundering, terrorist financing, and other illegal activities. Just Access is committed to complying with all applicable AML laws and regulations, and this policy serves as a guide for all employees, users, and partners interacting with our platform.

1. Purpose The purpose of this policy is to establish internal procedures and controls to prevent the use of Just Access services for money laundering, terrorist financing, or any other illicit activities. This policy also ensures that Just Access complies with relevant AML laws and regulations.

2. Customer Due Diligence (CDD) Just Access performs customer due diligence measures to identify and verify the identity of users, including:

• Know Your Customer (KYC) Protocol: Users must provide valid identification and information such as name, address, and government-issued ID.
• Ongoing Monitoring: Transactions are monitored for suspicious activity, including unusually large transactions, frequent transfers, or suspicious patterns that deviate from normal activity.
• Verification of Ownership: When using closed-loop cards, virtual wallets, or cryptocurrency, users are required to provide proof of ownership and control over the assets used for transactions.

3. Risk-Based Approach Just Access adopts a risk-based approach to AML. This means that:

• Users are classified based on their risk profile, and enhanced due diligence is performed for high-risk users.
• The platform implements strict transaction limits and flags unusual or suspicious transactions.
• Enhanced verification measures are implemented for high-value transactions.

4. Reporting Suspicious Activity All employees and users are required to report any suspicious activity or transaction that could indicate money laundering or terrorist financing. Just Access will:

• File Suspicious Activity Reports (SARs) with the relevant authorities when required.
• Freeze any account where suspicious activity is detected until investigations are completed.

5. Record Keeping Just Access maintains comprehensive records of all transactions, customer identification documents, and communications for at least 5 years. This ensures that the company can provide evidence of due diligence and compliance if required by regulatory authorities.

6. Training and Compliance All employees involved in handling transactions, customer verification, or monitoring are regularly trained on AML laws and practices. Just Access ensures continuous updates on regulatory changes to remain compliant.

7. Sanctions Compliance Just Access adheres to all international and national sanctions lists. Any user or transaction linked to sanctioned individuals, entities, or countries will be denied access to the platform.