AML/KYC Policy

Klaverchain Inc. ("Klaverchain," "we," "our," or "us") is committed to complying with all applicable Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Know Your Customer (KYC) laws and regulations in every jurisdiction in which we operate. This policy establishes the framework by which Klaverchain detects, prevents, and reports activities that may constitute money laundering, terrorist financing, or other financial crimes. All users, employees, contractors, and agents of Klaverchain are expected to adhere to this policy. Our AML/KYC program is designed in accordance with: • The Bank Secrecy Act (BSA) and its implementing regulations. • Financial Crimes Enforcement Network (FinCEN) guidance for money services businesses. • FATF (Financial Action Task Force) Recommendations. • Applicable state and international regulations.

Before establishing a business relationship, we are required to verify the identity of each customer. The Customer Identification Program (CIP) requires us to collect and verify: For Individual Users: • Full legal name. • Date of birth. • Residential address (no P.O. boxes). • Government-issued photo identification (passport, national ID, driver's license). • Tax identification number (e.g., SSN, ITIN, or equivalent). For Business Entities: • Legal business name and any trade names. • Principal place of business address. • Tax identification number (EIN or equivalent). • Formation documents (articles of incorporation, operating agreement). • Identification of beneficial owners (individuals owning 25% or more). • Identification of the controlling individual responsible for the entity. We reserve the right to request additional documentation to satisfy our verification requirements.

In addition to identity verification, Klaverchain performs risk-based Customer Due Diligence on all users. CDD involves: • Understanding the nature and purpose of the customer relationship. • Assessing the expected transaction patterns and volumes. • Identifying the source of funds when required. • Conducting ongoing monitoring of account activity for suspicious patterns. Standard Due Diligence applies to lower-risk customers with typical transaction profiles and standard use cases. Enhanced Due Diligence (EDD) is required for: • Politically Exposed Persons (PEPs) and their close associates. • Customers from high-risk jurisdictions as identified by FATF, FinCEN, or our internal risk model. • Customers whose transaction patterns indicate elevated risk. • Transactions above applicable thresholds or involving high-value assets. • Customers whose business activities present inherently higher risk. EDD may include requests for source-of-wealth documentation, in-depth background checks, and senior management approval.

A Politically Exposed Person is an individual who holds or has held a prominent public position, including heads of state, government ministers, members of parliament, senior military officers, senior executives of state-owned enterprises, and their immediate family members and close associates. Klaverchain applies enhanced scrutiny to all PEP accounts. This includes: • Senior management approval before onboarding. • Enhanced due diligence, including source-of-wealth verification. • Ongoing enhanced transaction monitoring. • Periodic review no less than annually. PEP status does not automatically disqualify a customer from using our services; however, it triggers a heightened level of oversight to manage associated risks.

Klaverchain screens all customers and transactions against applicable sanctions lists, including: • U.S. Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list. • EU Consolidated Sanctions List. • UN Security Council Consolidated Sanctions List. • HM Treasury Financial Sanctions List (UK). • Other applicable national and international sanctions programs. Screening is performed at account onboarding, at each transaction, and on an ongoing basis as lists are updated. Any potential match triggers an immediate review by our compliance team. Confirmed matches result in account suspension, transaction blocking, and mandatory reporting to relevant authorities. We do not provide services to individuals or entities in jurisdictions subject to comprehensive OFAC sanctions, including but not limited to Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions of Ukraine.

Klaverchain employs automated and manual transaction monitoring to detect suspicious activity. Monitoring rules include, but are not limited to: • Transactions that appear structured to evade reporting thresholds (structuring/smurfing). • Rapid movement of funds with no apparent business purpose. • Transactions inconsistent with the customer's stated profile or account history. • Use of multiple accounts to aggregate or layer funds. • Transactions involving high-risk counterparties or jurisdictions. • Abnormal patterns in crypto-to-fiat or fiat-to-crypto conversion activity. Alerts generated by our monitoring system are reviewed by our compliance team. Unresolved alerts may result in account restrictions while the review is conducted.

Where we identify activity that we know, suspect, or have reason to suspect may constitute money laundering, terrorist financing, or other financial crimes, we are required to file a Suspicious Activity Report (SAR) with the Financial Crimes Enforcement Network (FinCEN) or equivalent authority in the applicable jurisdiction. Tipping-off prohibition: We are legally prohibited from informing the customer that a SAR has been filed or that an investigation is underway. If you contact us regarding a frozen account or restricted transaction, we may be unable to provide a detailed explanation. Currency Transaction Reports (CTRs): We are required to file CTRs for cash transactions exceeding $10,000 USD in a single day (or structured to avoid this threshold). Reports are filed as required under applicable law, and we cooperate fully with law enforcement requests made through proper legal channels.

In compliance with applicable AML regulations, Klaverchain retains the following records: • Identity verification records: Minimum of 5 years from account closure or the end of the business relationship. • Transaction records: Minimum of 5 years from the date of each transaction. • SAR and CTR filings: Minimum of 5 years from the date of filing. • Correspondence related to compliance: As required by applicable law. Records are stored securely and are made available to regulators and law enforcement upon lawful request.

The following activities are strictly prohibited on the Klaverchain platform: • Money laundering or any activity intended to conceal the origin of illicit funds. • Financing of terrorism or proliferation of weapons of mass destruction. • Processing transactions on behalf of sanctioned individuals, entities, or jurisdictions. • Deliberate structuring of transactions to avoid reporting requirements. • Use of our platform to facilitate tax evasion or fraud. • Providing false or misleading information during the identity verification process. Engaging in any of the above activities will result in immediate account termination, asset freeze, and mandatory reporting to law enforcement authorities.

Klaverchain has designated a Chief Compliance Officer (CCO) who is responsible for: • Overseeing the implementation and effectiveness of this AML/KYC program. • Ensuring ongoing training of relevant staff. • Maintaining relationships with regulators and law enforcement. • Reviewing and updating this policy at least annually or as regulations change. • Reviewing and approving high-risk account relationships. Contact: For compliance-related inquiries, contact us at compliance@klaverchain.com.

All Klaverchain employees and contractors who handle customer accounts or transactions are required to complete AML/KYC training upon hire and at least annually thereafter. Training covers: • Recognition of money laundering red flags and suspicious activity indicators. • Applicable legal obligations and reporting requirements. • Customer due diligence procedures. • Sanctions screening and escalation procedures. • Internal reporting channels and whistleblower protections.

This AML/KYC Policy is reviewed and updated at least annually to reflect changes in applicable law, regulatory guidance, and best practices. Material changes will be communicated to users where required by law or regulation. Continued use of our platform constitutes acceptance of the current version of this policy. For questions about this policy, contact our compliance team at compliance@klaverchain.com.