Anti-Money Laundering Policy Statement

TopTier Trader is committed to the prevention and active deterrence of money laundering, terrorist financing, and any illicit financial activity that could compromise regulatory compliance and business integrity. We fully comply with all applicable Bank Secrecy Act (BSA) regulations, Financial Industry Regulatory Authority (FINRA) rules, and international standards, including those governing Designated Non-Financial Businesses and Professions (DNFBPs) in the United Arab Emirates (UAE).

To enhance our compliance framework, TopTier Trader has established this Anti-Money Laundering (AML) policy, which outlines mandatory measures to ensure the efficient implementation of guidelines that uphold both regulatory adherence and the achievement of organizational objectives. This policy extends to all entities in which TopTier Trader holds ownership interests.

TopTier Trader's AML policy is designed to:

1. Establish precise and unambiguous guidelines for combating money laundering, terrorist financing, and sanction evasion.
2. Define clear compliance responsibilities that all employees must fulfill.
3. Provide comprehensive guidance to employees on conducting daily business activities in full alignment with legal and regulatory requirements.
4. Promote a compliance-driven corporate culture, ensuring that all business operations are executed with a strong commitment to legal and ethical standards.

In accordance with Article 2 of the Anti-Money Laundering (AML) Law, money laundering is the intentional engagement in any of the following acts, with knowledge that the funds involved originate from criminal activity:

• Transferring or moving illicit proceeds with the intent to conceal or disguise their origin.
• Concealing or misrepresenting the true nature, source, or location of the funds, including the manner of disposal..
• Acquiring, possessing, or using illicit proceeds after receiving them.
• Aiding individuals involved in criminal activities in evading prosecution or punishment.

TopTier Trader recognizes that money laundering is always an intentional act, and cannot occur due to mere negligence. However, we acknowledge that gross negligence—particularly the failure to report suspicious activity to the Financial Intelligence Unit (FIU)—may lead to criminal liability.

Money laundering typically occurs in three stages:

1. Placement – Introducing illicit funds into the financial system, often through conversion into monetary instruments or deposits into financial institutions.
2. Layering – Conducting complex transactions to obscure the criminal origins of the funds, such as transferring them between multiple accounts or institutions.
3. Integration – Reintroducing the laundered funds into the economy, often by purchasing assets, investing in businesses, or funding further criminal activities.

Unlike traditional money laundering, terrorist financing may involve legally obtained funds but seeks to obscure their source or intended use for criminal activities. Terrorist financing can derive from:

• Charitable donations
• Foreign government sponsorship
• Business ownership and personal employment

Though the motivations differ, the methods used for terrorist financing often overlap with those employed by money launderers, including the use of shell companies, fraudulent transactions, and cash smuggling. Unlike traditional money laundering, terrorist financing may involve smaller transaction amounts, making detection more challenging.

The laws which TopTier Trader is subjected to and with which TopTier Trader comply:

• UAE Federal Law No. 20 of 2018: Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organizations (AML Law).
• Cabinet Resolution No. 10 of 2019: Implementing Regulations of Federal Law No. 20 of 2018 (AML Regulations)
• UAE Federal Law No. 7 of 2014: Combating Terrorism Crimes
• UAE Federal Penal Law No. 3 of 1987 as amended (Penal Code)
• UAE Federal Penal Procedures Law No. 35 of 1992 as amended (Penal Procedures Law)
• UAE Federal Law No. 5 of 2012: Combating Cyber Crimes
• SCA Decision (17/R) of 2010 Concerning Anti-Money Laundering and Terrorism Finance Combating Procedures
• UAE Central Bank Regulations Concerning Procedures for Anti-Money Laundering
• Any United Nations sanctions that are applicable through ratification by the UAE

Pursuant to the Regulations, it is mandated for financial institutions in the United Arab Emirates (UAE) to adopt a risk-based approach in order to fulfill their legal obligations. This requirement applies to various activities such as customer onboarding and conducting periodic anti-money laundering (AML) assessments throughout the course of business operations. TopTier Trader is fully committed to implementing a robust and meticulous risk-based compliance program, in strict accordance with both legal mandates and industry-leading best practices.

In the United Arab Emirates (UAE), the Financial Intelligence Unit (FIU), under the UAE Central Bank, is responsible for overseeing the reporting and investigation of suspected financial crimes, including money laundering and terrorist financing. The Public Prosecution has the exclusive authority to initiate legal proceedings against individuals or entities suspected of such offenses. These cases are prosecuted through the criminal courts system, ensuring strict enforcement of AML laws.

The UAE's Anti-Money Laundering (AML) Regulations do not provide specific legal defenses exclusive to money laundering charges. Defendants in money laundering cases are subject to the same legal protections and defenses as those accused of other criminal offenses.

Importantly, money laundering cases cannot be resolved through settlement or plea agreements. Once the Public Prosecutor determines that an offense constitutes money laundering, they are obligated to proceed with prosecution without discretionary authority to dismiss or negotiate charges.

TopTier Trader has implemented a robust transaction monitoring system to detect and flag any suspicious or unusual financial activities.

• Current Process: Transactions are reviewed manually using daily .csv transaction reports, with all activity undergoing thorough examination for anomalies. The Veriff Identity Verification Service is utilized to support due diligence during this process.
• Future Enhancement: To improve efficiency, TopTier Trader is committed to deploying an automated transaction monitoring system, ensuring real-time detection of suspicious transactions and minimizing the risk of financial crime.

TopTier Trader primarily operates in a retail business-to-consumer (B2C) model. In compliance with regulatory requirements, every transaction undergoes a meticulous manual approval process based on due diligence principles.

This rigorous approach ensures:

• Identification of abnormal, irregular, or potentially suspicious transactions.
• Prevention of financial crimes such as money laundering and terrorist financing.
• Compliance with international and UAE-specific AML regulations.

TopTier Trader adheres to its legal obligation to report any suspicious financial activities to the appropriate authorities.

• Reports of suspicious transactions are submitted to The Central Bank of the UAE via our banking partner.
• TopTier Trader ensures timely submission of all reports, utilizing secure email communication channels established for regulatory reporting.

To ensure compliance with legal and regulatory obligations, TopTier Trader maintains secure records of all AML-related transactions and activities for a minimum period of five years. This includes:

• Customer identification and verification records.
• Transaction history and due diligence documentation.
• Internal reviews and regulatory filings.

These records remain available for compliance audits, legal proceedings, and investigative purposes.

TopTier Trader has a dedicated risk management team responsible for conducting detailed risk assessments of individual client profiles.

• Manual Risk Assessment: Every customer undergoes comprehensive due diligence after an initial risk rating evaluation.
• Ongoing Monitoring: Customers with higher risk profiles are subject to Enhanced Due Diligence (EDD), which includes more frequent reviews and additional documentation requirements.

This proactive approach allows TopTier Trader to identify, assess, and mitigate financial crime risks effectively while ensuring compliance with applicable regulatory frameworks.

Failure to comply with AML regulations may result in strict administrative sanctions, including:

• Official warnings from regulatory authorities.
• Monetary fines imposed by enforcement agencies.
• Restrictions or suspension of business operations.
• Legal actions against board members and senior management responsible for compliance failures.
• Regulatory intervention, including the appointment of an independent observer to oversee operations.

Under UAE AML Law, individuals or entities convicted of money laundering offenses may face:

• Financial penalties ranging from AED 100,000 to AED 10 million.
• Imprisonment for up to 10 years, depending on the severity of the offense.

TopTier Trader strictly adheres to AML laws to prevent financial misconduct and avoid legal repercussions.

TopTier Trader is committed to:

1. Identifying potential financial crime risks within its operations.
2. Conducting ongoing assessments of these risks.
3. Implementing internal controls and policies to manage financial crime risks effectively.
4. Applying rigorous due diligence procedures to prevent illicit activities.
5. Complying with all United Nations (UN) directives related to terrorism financing and the prevention of weapons of mass destruction (WMD) proliferation.

To mitigate financial crime risks, TopTier Trader:

• Conducts rigorous manual transaction reviews to ensure transparency.
• Prevents business relationships with shell banks or organizations lacking physical presence and regulatory oversight.
• Implements enhanced scrutiny of entities operating in high-risk jurisdictions.

TopTier Trader mandates annual AML and Countering the Financing of Terrorism (CFT) training for all employees.

Training covers:

• Identification and reporting of transactions requiring regulatory disclosure.
• Examples of money laundering and terrorist financing schemes relevant to TopTier Trader's services.
• Internal policies and procedures for preventing financial crimes and escalating suspicious activity reports.

TopTier Trader maintains detailed training records, including:

• Attendance logs.
• Training materials.
• Documentation of updates on new or amended AML/CFT laws.

Ensuring that employees remain well-informed on compliance requirements strengthens TopTier Trader's ability to prevent financial crimes effectively.

TopTier Trader has established a Risk Management Team responsible for regular compliance testing to ensure alignment with UAE and international AML regulations.

A Designated Compliance Officer (DCO) is responsible for:

• Overseeing the AML/CFT program.
• Coordinating internal compliance operations.
• Ensuring regulatory reporting obligations are met.

Through continuous monitoring and proactive compliance measures, TopTier Trader upholds global AML standards, ensuring transparency and integrity in its financial operations.