TEFS TECHNOLOGY SERVICES

ANTI-MONEY LAUNDERING (AML) & KNOW YOUR CUSTOMER (KYC) POLICY

1. Introduction & Operational Scope

TEFS (the "Company") does not tolerate financial crime and strictly adheres to relevant intergovernmental standards to deter, detect, and report fraudulent or suspicious activities.

The Company operates exclusively within the technology and educational software sector, providing simulated trading evaluation environments. The Company is not a bank, broker-dealer, asset manager, or financial intermediary. It does not manage, hold, or accept retail client deposits, nor does it execute live financial market transactions. However, to ensure platform integrity and satisfy institutional payment processing partners, the Company enforces strict Anti-Money Laundering (AML) and Know Your Customer (KYC) safeguards.

2. Core Prevention Standards & Payment Rules

To eliminate the risk of platform abuse for the purpose of money laundering, the Company enforces strict rules regarding how funds enter and leave the system:

• No Client Capital Custody:

Users pay to access software evaluation challenges. All user activity is strictly confined to a simulated interface using virtual demo capital. Challenges do not grant the user any monetary reward.

• Prohibited Payment Methods:

The Company does not accept cash, bank checks, money orders, third-party bank transfers, or anonymous traditional transfer networks (e.g., Western Union).

• Cryptocurrency Safeguards:

Mainstream digital assets are accepted for service acquisitions and contract payouts under strict conditions:

• Crypto payments must originate from verified accounts at regulated exchanges or risk-scored self-custody wallets.
• The use of privacy coins (e.g., Monero, Dash) is prohibited.
• The Company uses blockchain analytics to systematically block transactions interacting with mixing protocols (e.g., Tornado Cash), darknet marketplaces, or sanctioned smart contracts.

• Strict Closed-Loop Disbursements:

Any contract-based independent contractor payouts are paid to the exact same financial account, payment card, or verified wallet used for the initial purchase. Third-party distributions are strictly prohibited.

3. Know Your Customer (KYC) & Identity Verification

To minimize user friction upon onboarding, the Company does not require identity verification during registration, evaluation, or upon transitioning to a funded simulation account. However, to prevent fraud or money laundering, the submission and successful clearance of comprehensive KYC documentation is strictly mandatory if and when a user initiates a formal contractual payout request. No funds will be disbursed until the user provides:

• Proof of Identity:

A valid, government-issued photographic ID confirming full legal name and date of birth (e.g., Passport, Driver's License, or National ID).

• Proof of Residence:

A valid utility bill or bank statement issued within the last 90 days confirming a physical residential address matching the user profile.

• Payment Instrument Verification:

Proof of ownership of the payment method used (e.g., confirming the account holder's name or the last 4 digits of the card used for initial service acquisition).

All the above must match the initial User payment details (name and payment method details).

Failure to pass KYC, or submitting fraudulent data, will result in immediate forfeiture of the account, cancellation of the payout request, and contract termination.

4. Sanctions, PEP, and Geographic Screening

The Company utilizes the following passive technical controls at registration:

• Geographic Restrictions (At Entry):

The Company enforces automated IP and firewall blocking to systematically prevent platform access, registration, or purchases from users inside OFAC-sanctioned jurisdictions (e.g., Russia, Iran, North Korea, Syria, Cuba, occupied regions of Ukraine) and high-risk jurisdictions designated by the FATF.

The Company utilizes additional identity screening when a payout is requested, namely, receiving user declaration of not being under sanctions, PEP or from forbidden GEO locations:

• Global Watchlists & Sanctions (At Payout):

Upon a payout request, the verified legal identity obtained via KYC is cross-referenced against global sanctions registries. The Company will immediately reject payouts and terminate contracts for any individual matched against registries for terrorism or financial crime.

• Politically Exposed Persons (PEPs):

Enhanced operational review is conducted at the payout stage if a verified user is flagged as a Politically Exposed Person or a close associate of an official in a high-risk jurisdiction.

5. Risk Red Flags & Continuous Monitoring

The Company tracks operational and purchase data to detect anomalies. Internal alerts are triggered by specific platform "Red Flags," including:

• Structuring Attempts:

A single user making consecutive micro-purchases or opening multiple accounts under variations of a single name using the same payment card or IP address.

• Account/Proxy Structuring:

Multiple separate user accounts logging into the simulation platform from identical hardware node signatures, physical device IDs, or proxy/VPN locations (indicating unauthorized account sharing or bot manipulation).

• Unusual Velocity:

Drastic, sudden variations in purchase volumes relative to standard user baselines.

6. Freezing, Regulatory Cooperation, & Data Retention

• Account Freezing:

The Company reserves the absolute right to freeze platform activity, suspend technology access, and withhold payouts immediately upon suspicion of irregular or manipulative transaction patterns, pending a formal review.

• Regulatory Cooperation:

If an internal audit reveals conclusive indicators of fraud or illicit intent, the Company will cooperate fully with law enforcement subpoenas and applicable administrative authorities.

• Data Retention Policy:

All verification records, identity documents, platform transaction logs, and IP access signatures are securely archived and retained for a mandatory minimum period of seven (7) years following account closure.

These guidelines have been implemented to protect TEFS and its clients.

For inquiries regarding these compliance guidelines, contact our Internal Compliance Department at [email protected].