AML Policy

Anti-Money Laundering Policy

This Anti-Money Laundering Policy (“Policy”) is a part of our voluntarily applied regime to prevent money laundering, terrorist financing, fraud, or any other financial crime as well as to prevent usage of our services (as specified below) of any ineligible persons, underaged person, to prevent usage of our services of individuals or entities from the prohibited or high-risk jurisdictions.

References in these Terms to “we”, “our” or “us”, are to AptosLaunch Labs Ltd., the British Virgin Islands limited company, and references to “you”, “your” are to the person, including both individuals and entities using our services, software and applications.

Upon accessing or using AptosLaunch Software or registration of your AptosLaunch Wallet, you agree to be legally bound by and to comply with this Policy. This Policy can be amended from time to time at our sole discretion. All the definitions used in this Policy shall have the same meaning as in our Terms of Service unless this Policy sets a different meaning.

This Policy applies to your usage of the Launchpad, Launchpool and/or your participation in the sale and/or distribution of Tokens. We may apply this Policy to your use of our software applications and/or services, not specifically mentioned in this Policy, at our sole discretion.

1. Definitions

1. “Token” means the Digital Asset issued by the third party that is offered, sold or distributed through Launchpad and Launchpool.

2. The term “entity” shall include any business, partnership, joint venture, agency, association, firm, corporation, limited liability company or other entity of any kind.

2. Identification and Verification

1. The performance of identity verification is an essential part of our anti-money laundering regime. We may require you to pass identity verification prior we allow you to use the functionality of Launchpad or Launchpool, participate in the sale and/or distribution of Tokens and at any moment thereafter. Also, we may require you to pass identity verification prior we allow you to use our software, applications and our other services and at any moment thereafter.

2. For the purposes of this Policy we may require you to provide us with the following information: first name, last name, address, telephone number, e-mail address, date of birth, taxpayer identification number, a government identification, and, if applicable, information regarding your bank account (such as the name of the bank, the account type, routing number, and account number). Also, we may request from you your driving license or any other national ID, internal or international passport, bank statement, utility bill, tax document and/or other documents that we consider necessary for your identification. We may request from you video identification or your selfie with a specified ID or passport.

3. When you act on behalf of an entity, in addition, we may require such entity to pass entity verification prior we allow such entity to use the functionality of Launchpad or Launchpool, participate in the sale and/or distribution of Tokens and at any moment thereafter. In this case, we may require you to provide us with the following information: business name of the entity, registry code or registration number and the date of registration; ID of the shareholders (same as for the natural person identification), ID of the director(s) and/or members of the management board (same as for the natural person identification), ID’s of the representatives (same as for the natural person identification), proof of the registered office/seat of the entity, ID’s of the beneficial owners (same as for the natural person identification), bank statements, proof of representation and powers; articles of association and/or other information and documents that we consider necessary.

4. The submitted documents (other than driving license, national ID, internal or international passport) should be issued no more than three months prior to the date of identification and should list your name and your current address. In providing us with this or any other information that may be required, you confirm that the information is accurate and authentic. You agree to keep us updated if any of the information or document you provide changes.

5. You acknowledge and agree that we may use subcontractors for the purpose of your identity verification. In this case processing of the requested information and documents would be governed by such subcontractor’s privacy policy and you would be able to read such privacy policy before you submit any information.

6. You hereby agree to provide us or our subcontractors with the information we or our subcontractors request and you hereby permit us and our subcontractors to keep a record of such information.

7. You authorise us and our subcontractors to make inquiries, whether directly or through third parties, that we and our subcontractors consider necessary to verify your identity, to ensure enforcement of geographic restrictions or protect you and/or us against fraud or other financial crime, and to take action we reasonably deem necessary based on the results of such inquiries.

8. We shall have the right to verify your identity on an on-going basis, including cases when your identification information has been changed or your activity seemed to be suspicious (unusual for you). We reserve the right to request up-to-date documents from you and/or represented entity, even though you have passed identity verification in the past.

3. Restricted and High-Risk Regions.

1. We will refuse you to access and/or use Launchpad, Launchpool and related services, will not allow you to acquire Tokens and/or take part in the sale and/or distribution of Tokens if you are:

   1. a citizen, a permanent resident or located in Afghanistan, Democratic Republic of Congo, Cuba, Democratic People’s Republic of Korea, Islamic Republic of Iran, Republic of Iraq, Puerto Rico, Syrian Arab Republic, Zimbabwe, United States of America (including its states and the district of Columbia), the Virgin Islands of the United States, or any other possessions of the United States of America;

   2. a citizen, a permanent resident or located at any state, country, territory or other jurisdiction that is embargoed by the United Nations;

   3. a citizen, a permanent resident or located at any state, country, territory or other jurisdiction where your purchase, ownership and/or use of Tokens would be illegal or otherwise violate any applicable law;

   4. an entity established at or carrying day-to-day management from any state, country, territory or other jurisdiction, specified in subsections (i)-(iii) of this Section;

   5. you are restricted or barred from conducting banking or financial transactions, in any jurisdiction or under any applicable laws;

   6. you are placed on any list of suspicious persons banned from travelling or conducting business or financial transactions in any jurisdiction;

   7. you are a politically exposed person (“PEP”) or a person connected with the PEP;

   8. a representative of any of such persons specified in subsections (i)-(vii) of this Section.

2. Also, we may not allow you to acquire Tokens and/or take part in the sale or distribution of Tokens, if you are a citizen, permanent resident or located in the country which based on various criteria selected by our anti-money laundering team as imposing anti-money laundering or counter-terrorist financing high risk (for example Corruption Perceptions Index by Transparency International, FATF warnings, countries with weak anti-money laundering and terrorist financing regimes determined by British Virgin Islands authorities) or you are an entity established at or carrying day-to-day management from such country.

4. Refusal

1. You hereby acknowledge and agree we shall have the right at any stage of the process and/or at any moment to cease any transfer or distribution of Tokens to you and terminate your participation in the sale and/or distribution of Tokens without the obligation of any refunds to you in the following cases:

   1. you provided us with false or incomplete information, you are reluctant to provide complete information or you refused to provide us with any requested information;

   2. you are or become a citizen of, a permanent resident of, or your entity’s day-to-day management is transferred to any of country, territory or jurisdiction specified in subsections (i)-(iii) of Section 3(a) or in the Section 3(b);

   3. you are or become restricted or barred from conducting banking or financial transactions, in any jurisdiction or under any applicable laws;

   4. you are or were placed on any list of suspicious persons banned from travelling or conducting business or financial transactions in any jurisdiction;

   5. you are or become a politically exposed person (“PEP”) or a person connected with the PEP;

   6. you made a payment from cryptocurrency wallets or crypto assets wallets placed at common blacklists or having known security discrepancies;

   7. we have the suspicion that you are engaged in illegal activity or you using funds that come from illicit sources.

2. We shall have no liability to you for any damage caused by such cessation of transfer of Tokens to you.

5. Monitoring Transactions. Reporting

1. We may monitor and analyse your transactions and blockchain wallets activity. We may perform compliance-related tasks, including capturing data, filtering, record-keeping, investigation management and reporting. We may place you on watch and service denial lists, open cases for investigation where needed, send internal communications and fill out statutory reports, if applicable.

2. We may check addresses of your blockchain wallets against common blacklists and known security discrepancies, to ensure that the funds do not come from illicit sources, and there are no signs of money laundering (location, layers, integration), either manually or using a third party service.

3. We shall have the right to report your transactions of suspicious nature to the proper law enforcement authorities, request you to provide any additional information and documents in case of suspicious transactions.

6. General Terms

1. We may modify this Policy by providing notice of such changes, such as by sending you an email, providing notice through any of our websites, or by updating the “Last Updated” date at the bottom of this Policy.

2. You acknowledge that our decision to take certain actions according to this Policy may be based on confidential criteria that are essential to security protocols or crime investigation. You agree that we are under no obligation to disclose the details of our security procedures to you.

Last Updated: 22 December 2022