Date: 09 September 2025

Matrixport Technologies Ltd and its affiliated entities ("Matrixport") are committed to preventing Money Laundering (ML) and Terrorist Financing (TF), and complying with applicable Anti-Money Laundering (AML), Countering Financing of Terrorism (CFT) and sanctions requirements. These obligations, together with relevant regulatory guidance, form the basis of Matrixport's AML/CFT Program.

The AML/CFT Program applies across all jurisdictions in which we operate and establishes a risk-based framework of governance, policies, procedures, and internal controls to identify, assess, and mitigate financial crime risk, including measures addressing proliferation financing and sanctions compliance.

Key Components of our AML/CFT Program

1. AML/CFT Policy

The AML/CFT Policy sets minimum standards that apply across Matrixport and includes:

Written policies, procedures, and internal controls to ensure compliance with applicable AML/CFT and sanctions laws.

Accountability: Appointment of a Money Laundering Reporting Officer (MLRO) and designated Compliance Officers responsible for day-to-day effectiveness.

Governance: A robust framework with Senior Management oversight of the AML/CFT Program.

Customer Due Diligence (CDD): Identification and verification of customers, authorised representatives, and (where applicable) beneficial owners; collection of purpose of account, expected activity, source of funds, and, where appropriate, source of wealth at onboarding.

Risk Assessment: Customer, product, service, delivery channel, and geographic risk assessments.

Enhanced Due Diligence (EDD): Applied to higher-risk relationships (e.g., PEP nexus, high-risk industries/jurisdictions, adverse media, elevated risk factors from Know Your Transaction (KYT) / transaction monitoring (TM)).

Sanctions Compliance: Screening and controls consistent with applicable sanctions regimes, including obligations related to proliferation financing.

Escalation & Reporting: Internal escalation and timely filing of suspicious transaction/activity reports with the relevant authorities.

Ongoing Due Diligence: Periodic reviews (PRs) based on risk rating and trigger events.

Training: Mandatory AML/CFT and sanctions training for all employees at onboarding and annually thereafter.

Independent Testing: Periodic, independent audit/review of program effectiveness.

Recordkeeping: Retention of records for the periods required by applicable law and regulations.

Travel Rule (where applicable): Transmission of required originator/beneficiary information between VASPs/financial institutions.

2. Prohibited Uses, Customers and Businesses

Prohibited Business Relationships
Matrixport will not conduct business relationships with the following client types:

• Sanctioned individuals and entities by the BVI authorities or under International Sanctions lists (e.g. United Nations Security Council, United States Office of Foreign Asset Control (OFAC), EU Sanctions, His Majesty's Treasury of the United Kingdom, Monetary Authority of Singapore lists and etc)
• Persons or enterprises known or reasonably presumed to be involved in terrorist financing or serious criminal activity, or that belong to/support such organisations
• Shell banks which have no physical presence at their place of incorporation
• Clients operating under fictitious names or pseudonyms
• Clients that are in Weapons, Armament Manufacturers, Armament Trading
• Clients involved in Tobacco trading
• Clients involved in Adult Entertainment
• Clients involved in Casinos, Gambling or similar industries

Prohibited Assets
Matrixport will not allow funds, of which it knows via its Know Your Transaction (KYT) monitoring or KYC (Know Your Client) checks to be the proceeds of crime, used for terrorist financing, or linked to criminal organisations to enter or remain within a client relationship, even if the underlying offence occurred abroad.

Restricted Jurisdictions
Matrixport does not onboard clients from restricted jurisdictions (e.g., those subject to comprehensive sanctions or presenting severe AML/CFT deficiencies). The current list is maintained on our Help Center https://matrixport.helpjuice.com/en_US/360004598793-getting-started/360039268014-Matrixport-Restricted-Countries and reviewed at least annually.

3. Know Your Transactions (KYT) at Matrixport

Matrixport prohibits the use of its platforms for illegal activity, including money laundering, terrorist financing, or unlawful commerce. We perform real time and ongoing KYT and transaction monitoring of all users transactions. Where monitoring identifies suspected illegal activity, Matrixport may take action, including rejecting or refunding funds, issuing requests for information (RFIs), freezing accounts, suspending or terminating access or relationships, and/or reporting suspicious activity to the relevant authorities, where permitted by applicable law and our Terms and Conditions. Matrixport reserves all rights under applicable law and its contractual arrangements.

4. Prohibited Activity

The following activities are prohibited on Matrixport platforms, including but not limited to:

• Transactions that may violate, or cause Matrixport to violate applicable economic sanctions imposed or enforced by various governmental agencies including, but not limited to, those administered by the Office of Foreign Asset Control of the U.S. Department of Treasury, U.S. Department of State, the United Nations Security Council, the European Union member state, His Majesty's Treasury of the United Kingdom and the Monetary Authority of Singapore. This list is not exhaustive and also includes any other applicable sanctions programs in the jurisdictions where Matrixport operates.
• Transactions related to illicit activities, including fraud, scams, stolen funds, ransomware, malware
• Transactions involving mixers/tumblers, darknet markets, or other obfuscation services
• Transactions related to casinos, gambling or similar industries
• Transactions with irregular, unusual or uncommon transaction patterns and no logical business explanation