Overview & Purpose

Djooky Finance Limited ("Djooky Finance," "the Company," "we") is a Money Services Business (MSB) registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) under registration number C100000967.

The Company is incorporated in British Columbia, Canada (Incorporation No. BC1535602, Business No. 704053628BC0001) and is subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated regulations.

This Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) Policy establishes the framework by which the Company detects, prevents, and reports activities that may be related to money laundering (ML) or terrorist financing (TF).

Scope

This policy applies to all employees, contractors, officers, directors, and agents of Djooky Finance Limited, and covers all services offered by the Company including:

• Foreign currency exchange dealing
• Fund remittance and money transmission
• Virtual currency dealing, exchange, and transfer
• Crowdfunding platform services

Compliance Officer

Djooky Finance Limited has designated a senior individual as the Compliance Officer responsible for implementing and overseeing the AML/CTF compliance program.

Responsibilities of the Compliance Officer

• Developing and maintaining the AML/CTF compliance program
• Ensuring all policies and procedures comply with PCMLTFA requirements
• Overseeing client identification and due diligence processes
• Reviewing and approving suspicious transaction reports before submission to FINTRAC
• Organizing and maintaining AML training for all staff
• Conducting or commissioning periodic effectiveness reviews of the compliance program
• Acting as the primary point of contact for FINTRAC inquiries and examinations
• Keeping current on regulatory developments and updating policies accordingly

Client Identification (Know Your Customer)

Djooky Finance is required to identify and verify clients in accordance with PCMLTFA obligations. The Company applies a risk-based approach to client identification.

When Identification is Required

The Company must identify clients in the following circumstances:

• Foreign currency exchange transactions of CAD $3,000 or more
• Any fund transfers (domestic or international) of CAD $1,000 or more
• Virtual currency transactions of CAD $1,000 or more
• Receipt of cash of CAD $10,000 or more
• Any transaction where the Company suspects money laundering or terrorist financing
• Any new business relationship as defined by FINTRAC

Acceptable Identification Documents

Document Type	Issuing Authority	Verification Method
Passport	Federal government	Original or certified copy
Driver's License	Provincial/territorial	Original document
Permanent Resident Card	IRCC Canada	Original document
Provincial Health Card	Provincial authority	Where permitted
Foreign Passport	Foreign government	Original document
National Identity Card	Foreign government	Original document

Business Client Identification

For corporate or business clients, the Company collects and verifies:

• Legal business name and trade name (if applicable)
• Business registration or incorporation number
• Principal place of business address
• Nature of the principal business
• Names and identification of beneficial owners holding 25% or more of shares
• Names and identification of authorized signatories

Customer Due Diligence (CDD)

Standard Due Diligence

Standard CDD is applied to all clients and includes identity verification, understanding the nature and purpose of the business relationship, and ongoing monitoring of transactions.

Enhanced Due Diligence (EDD)

Enhanced due diligence is applied to higher-risk clients, including but not limited to:

• Politically Exposed Persons (PEPs) or their family members and close associates
• Clients from high-risk jurisdictions as identified by FATF
• Clients engaged in high-risk industries (gambling, cannabis, adult entertainment, arms dealing)
• Clients who have triggered suspicious transaction alerts
• Anonymous or unverified clients attempting transactions above thresholds
• Clients using privacy coins or mixers

EDD measures include senior management approval, source of funds and wealth documentation, more frequent transaction monitoring, and shorter review cycles.

Simplified Due Diligence

In limited circumstances prescribed by regulation, simplified due diligence may be applied where the risk of ML/TF is demonstrably low, such as for certain government entities or regulated financial institutions.

Transaction Monitoring

The Company maintains an ongoing transaction monitoring program designed to detect unusual or suspicious patterns of activity that may be indicative of money laundering, terrorist financing, or other financial crime.

Monitoring Indicators

The Company monitors for, among other things:

• Transactions structured to remain below reporting thresholds (structuring/smurfing)
• Rapid movement of funds through the account with no apparent business purpose
• Transactions inconsistent with the client's stated business or known financial profile
• Use of multiple wallets or accounts to obscure the origin of funds
• Clients unwilling to provide identification or explain the purpose of a transaction
• Transactions involving jurisdictions subject to FINTRAC or OFAC sanctions
• Unusual virtual currency activity patterns, including use of mixers or privacy coins
• Large cash or crypto deposits followed by immediate withdrawals

Blockchain Analytics

For virtual currency transactions, the Company employs blockchain analytics tools to assess the risk profile of incoming and outgoing digital assets, including screening against known illicit wallet addresses.

FINTRAC Reporting Obligations

Djooky Finance is required to submit the following reports to FINTRAC:

Report Type	Trigger	Deadline
Large Cash Transaction Report (LCTR)	Receipt of CAD $10,000+ in cash in a single transaction or multiple transactions within 24 hours	15 calendar days
Suspicious Transaction Report (STR)	Any transaction — completed or attempted — where there are reasonable grounds to suspect ML/TF	30 calendar days of detection
Electronic Funds Transfer Report (EFTR)	International EFT of CAD $10,000+ in a single or 24-hour period	5 business days
Virtual Currency Transaction Report (VCTR)	Receipt of virtual currency equivalent to CAD $10,000+ in a single or 24-hour period	5 business days
Terrorist Property Report (TPR)	Possession or control of property owned or controlled by a terrorist or terrorist group	Immediately

Record Keeping

The Company maintains comprehensive records as required by the PCMLTFA and its regulations. All records must be kept for a minimum of five (5) years from the date the record was created.

Records Maintained

• Client identification records and copies of identity documents
• Business relationship records including the nature and purpose of the relationship
• Transaction records for all foreign exchange, fund transfers, and virtual currency transactions
• Large cash transaction records
• Suspicious transaction records and documentation of the analysis conducted
• Electronic funds transfer records
• Virtual currency transaction records
• Copies of all FINTRAC reports submitted
• Employee training records
• Compliance program documentation and review records

Records are maintained in a secure, retrievable format and are made available to FINTRAC upon lawful request.

Politically Exposed Persons & Sanctions Screening

PEP Identification

A Politically Exposed Person (PEP) includes any individual who holds or has held one of the following positions:

• Head of state or government, or a member of the executive council of government
• Member of a legislative body
• Deputy minister or equivalent senior public servant
• Ambassador or attaché
• Senior military officer (General or above, or equivalent)
• President or senior executive of a state-owned enterprise
• Head or deputy head of an international organization
• Judge of a supreme or superior court

Family members and close associates of PEPs are also subject to enhanced scrutiny.

Sanctions Screening

The Company screens all clients and beneficial owners against:

• OSFI's Consolidated Canadian Autonomous Sanctions List
• United Nations Security Council sanctions lists
• OFAC SDN (Specially Designated Nationals) list
• FINTRAC's published high-risk country advisories

Any match triggers an immediate transaction freeze and escalation to the Compliance Officer. Business relationships with sanctioned individuals or entities are prohibited.

Virtual Currency Specific Obligations

As a registered virtual currency dealing business, Djooky Finance applies specific controls to all digital asset activities.

Travel Rule Compliance

For virtual currency transfers of CAD $1,000 or more, the Company complies with FINTRAC's Travel Rule requirements, collecting and transmitting originator and beneficiary information including:

• Full legal name of the originator
• Originator's account number or virtual currency wallet address
• Originator's address
• Beneficiary's full legal name
• Beneficiary's account or wallet address

Wallet Screening

The Company screens all wallet addresses involved in transactions against databases of known illicit addresses associated with ransomware, darknet markets, sanctions evasion, and other financial crime, using recognized blockchain analytics providers.

Prohibited Activities

The Company does not facilitate:

• Transactions involving mixer or tumbler services
• Transactions from or to wallets flagged as high-risk by blockchain analytics
• Transactions involving privacy coins where source cannot be verified
• Any transaction that appears designed to obscure the origin or destination of funds

Employee Training

All employees and contractors of Djooky Finance who handle transactions, interact with clients, or have access to client records are required to complete AML/CTF training.

Training Program Covers

• The Company's obligations under the PCMLTFA
• How to identify and handle suspicious transactions
• Client identification and due diligence procedures
• FINTRAC reporting requirements and procedures
• Record keeping obligations
• Confidentiality and non-tipping-off requirements
• Virtual currency-specific risks and typologies
• Consequences of non-compliance

Training is conducted upon onboarding and refreshed at least annually, or whenever there are material changes to the regulatory framework. Training completion records are maintained by the Compliance Officer.

Policy Review & Effectiveness Testing

The AML/CTF compliance program is reviewed at least every two years, or more frequently in response to:

• Material changes to PCMLTFA or FINTRAC regulations
• Significant changes to the Company's business model or services
• FINTRAC examination findings or guidance
• Identification of program deficiencies through internal audit

Effectiveness testing is conducted to assess whether the program is functioning as intended, including transaction sampling, staff knowledge assessments, and review of reporting patterns.

Contact & Reporting

To report suspicious activity, compliance concerns, or questions regarding this policy, contact the Compliance Officer:

To verify our FINTRAC registration, visit the FINTRAC MSB Public Registry and search for registration number C100000967.