SFX Anti Money Laundering Policy

Sora Financial Technologies Inc. United States 1111B S Governors Ave STE 26538 Dover, DE 19904 Reg:20244413314

Turkiye Turkiye, Samsun, YENIMAHALLE MAH. 3142 SK. SHT. ASB. ÖMER HALISDEMIR APT. NO: 3 IÇ KAPI Tax ID: 4651507062

SFX Anti-Money Laundering (AML) Policy

Last Updated: 10 February, 2025

Introduction

SFX is fully committed to preventing money laundering, terrorist financing, and any activities that facilitate these illegal practices. Our dedication aligns with the applicable laws and regulations of the customer's home countries and the domiciled countries, specifically Turkiye (Banking Act No. 5411), TRNC, and international standards. This comprehensive AML policy outlines our commitment and actions to achieve AML and CFT objectives effectively.

1. Money Laundering and Terrorist Financing

Money laundering and terrorist financing involve activities aimed at concealing or disguising the illicit origins of criminally derived funds to make them appear legitimate. These activities typically comprise three stages: "placement" (introducing cash into the financial system), "layering" (transferring funds to separate them from their criminal origin), and "integration" (reintroducing funds into the economy or using them for unlawful activities).

SFX acknowledges that the securities industry, though rarely involving cash transactions, might still be susceptible to money laundering attempts from external sources or through fraudulent activities within the industry itself. Additionally, we recognize that the motivations behind terrorist financing differ from traditional criminal organizations, though the methods used for funding may overlap.

2. AML Policies, Procedures, and Internal Controls

SFX has established a comprehensive AML program designed to ensure full compliance with the relevant laws and regulations of the customer's home countries and the domiciled countries, including the Banking Act No. 5411, the Payment Services Law No. 6493 in Turkiye, and the Law No. 5549 on Prevention of Laundering Proceeds of Crime. These policies, procedures, and internal controls are meticulously crafted to prevent money laundering and terrorist financing. We are committed to regularly reviewing and updating our AML program to stay in line with regulatory changes and evolving business operations.

3. AML Compliance Person Designation and Duties

SFX has designated Martins Chiwenyte Chidume as the Anti-Money Laundering Program Compliance Person (AML Compliance Person) entrusted with overseeing the firm's AML program. Martins Chiwenyte Chidume possesses the necessary knowledge, experience, and training to execute this role effectively. Duties of the AML Compliance Person include:

4. Monitoring SFX's compliance with AML obligations.

Supervising communication and training for employees, in collaboration with our partner AML/KYC firm, Smile ID.

Ensuring the firm keeps and maintains all required AML records.

Collaborating with Smile ID to file Suspicious Activity Reports (SARs) with the appropriate authorities.

The AML Compliance Person possesses full authority and responsibility for enforcing the firm's AML program.

5. Customer Identification Program (CIP)

SFX has implemented a robust Customer Identification Program (CIP) in compliance with the relevant laws and regulations of the customer's home countries and the domiciled countries. Our CIP encompasses advanced Know Your Customer (KYC) processes, which are conducted through Smile ID to ensure rigorous identity verification, including facial recognition, to prevent money laundering and terrorist financing activities.

5a. Required Customer Information

To achieve this, SFX collects the following required customer information as part of our comprehensive CIP and KYC processes:

Full Name: First name and last name as per official documents.

Date of Birth: To verify the customer's age.

Nationality: To establish the customer's legal status.

Address: The residential address, including P.O. Box.

Government-Issued Identification: An unexpired government-issued identification evidencing nationality or residence and bearing a photograph, such as a designated countries' passport (Tier 2), or a valid Turkish student, Short-term or long term residence permit ,Turkish driver’s license (Tier 3).

5b. Customers Who Refuse to Provide Information

SFX maintains a strict policy of verifying the identity of all customers to ensure AML compliance and platform security. Customers who refuse to provide the required information will not be allowed to open an account with SFX.

5c. Verifying Information

SFX employs Smile ID, a state-of-the-art digital identity verification solution, to authenticate customer information. The verification process comprises the following steps:

KYC Details Input: Users provide their name, date of birth, nationality, address, and P.O. Box during registration.

Live Passport Upload: Customers are required to upload their international passport live through SmileKYC for identity verification. Smile ID conducts automated screening for AML compliance, cross-referencing customer data against global and African sanctions lists, PEP lists, and adverse media watchlists.

5d. Comparison with Government-Provided Lists of Terrorists

In collaboration with Smile ID, SFX utilizes the integrated African Government KYC Check to verify users against reliable sources. This check accesses government ID databases across Turkiye and Africa and matches biometrics to enhance fraud mitigation while cross-referencing against government-provided lists of terrorists.

5e. Notice to Customers

Customers are promptly informed of the requirement to verify their identity as part of our AML and KYC procedures immediately upon registration into our platform.

6. Tiers of Security

Tier 1: Users provide their phone number, email, name, last name, and nationality. No transactions can be performed at this stage.

Tier 2: Users must provide an international passport or Home country driver’s license, or BVN for Nigeria. KYC details are verified periodically every 6 months to ensure document authenticity. 10,000 USD Daily withdrawal Limit, 50,000 USD Monthly Deposits.

Tier 3: Users must provide a valid Short term or Long term Turkish Resident Permit or a valid Turkish driver’s license and state the purpose for opening the account (User must provide source of income). 50,000 USD Daily withdrawal Limit.

6a. KYC Data Integrity

Only one set of KYC data can be matched to one user to prevent double onboarding. If this is not possible, the user cannot be onboarded, and no transactions can be performed.

Only one registered phone number or email can be linked to a user. This phone number is required to receive OTPs (One-Time Passwords).

6b. Understanding the Nature and Purpose of Customer Relationships

To develop a customer risk profile, SFX thoroughly comprehends the nature and purpose of customer relationships. This profile takes into account various factors, such as the customer's background, expected account activity, and financial transactions.

6c. Enhanced Due Diligence (EDD) for Higher-Risk Customers

For customers identified as higher risk, SFX employs enhanced due diligence (EDD) measures to more effectively manage and mitigate risk. These include:

Politically Exposed Persons (PEP)

Relatives and close family members of PEPs

High-Risk Customer Onboarding and Management

Customers flagged as high risk by our KYC and AML systems are not onboarded. Senior Management must sign off on the onboarding of high-risk customers. This includes a detailed review of the customer's profile and potential risks. For existing customers identified as high risk, Senior Management sign-off is required for their continued relationship with SFX.

Risk Rating Categories and Periodic Reviews

SFX uses a risk rating system to classify customers into high, medium, and low-risk categories based on AML check, Home Country (International Passport), Tier 2 or 3, transaction monitioring, BVN verification (Nigeria only), which is assigned to already banked Nigerians and can give us a picture of how they are ranked in their home country banking system.

7. Review Frequency

Monthly reviews are conducted during the last week of the month to ensure the risk rating is up to date and accurately reflects the customer's current risk level for the Month.

Periodic reviews are performed every 6 months for Tier 2 users to verify the authenticity of provided documents, such as driver's licenses and international passports.

Prohibition on Dealing with Shell Banks

SFX strictly prohibits dealing with shell banks, shell organizations, or any entities that offer services to shell banks. We do not engage in business with these entities under any circumstances.

8. Prohibited Countries

Influencer SFX does not onboard users from or engage in transactions with individuals or entities in the following countries and regions: Cuba, Iran, North Korea, Syria, Russia, Venezuela, and regions of Ukraine: Crimea, Donetsk, and Luhansk. Influencer SFX only supports and onboards users from African countries and ensures compliance with this requirement.

9. Reporting Suspicious Activities

SFX requires all employees and partners, including Smile ID, to report any transactions or activities that appear suspicious or possibly linked to money laundering or terrorist financing. Employees and partners are expected to remain vigilant and report any unusual or suspicious activities.

9a. Prohibition on Tipping Off

SFX strictly prohibits tipping off customers or any third parties about the fact that a Suspicious Activity Report (SAR) has been filed or that their transactions are being scrutinized for suspicious activity. Tipping off is illegal and undermines the investigation process.

9b. Reporting to Authorities

Suspicious activities relating to money laundering and terrorist financing are reported to the Turkish Authorities. SFX will also coordinate with our partners and tip off about any suspicious funds transfer and place a freeze on the account in question. Advisory will always be coordinated between our partners and the Turkish authorities at all stages.

9c. Handling Law Enforcement Requests

All requests from law enforcement or regulatory authorities (RFI requests) are handled by Martins Chiwenyte Chidume. Martins Chiwenyte Chidume will immediately notify the Chairman and Members of the Influencer SFx Board, Suspicious wallet transactions are flagged and reported to the necessary authorities in Turkiye, including local authorities in Samsun, and through the Chainalysis Blockchain Data Platform. Reports can be made through the Chainalysis reporting database, at state police offices, or to the office of the state prosecutors (Samsun) in Turkiye.

10. Customer Records Retention and data handling

SFX maintains all customer records and related documentation securely in accordance with regulatory requirements. These records include, but are not limited to, all customer identification information, transaction records, and reports of suspicious activities. Customer data required to be collected by the obliged financial institution is stated in the AML/CFT Regulation and data related to customer due diligence is retained for eight years or more, both in physical and digital formats. The retention period may be extended based on specific requirements from partners or law enforcement authorities.

10a.Independent Testing SFX conducts an independent review of its AML program by an external auditor at least once every two years. The external auditor evaluates the effectiveness of our AML policies and procedures, providing an objective assessment of our compliance.

10b. Employee Training SFX provides regular training to employees on AML and CIP requirements. Training includes webinars organized by Smile ID, YellowCard, complyadvantage, and live sessions organized by our partners. Employees are expected to stay informed about changes to regulations and SFX's AML policies and procedures.

10c. Cooperation with Law Enforcement and Regulators SFX collaborates with law enforcement agencies, government bodies, and regulators when there are reasonable grounds to suspect that funds are being used for illegal activities. We fully cooperate with authorities to help investigate and prosecute crimes related to money laundering or terrorist financing.

10d. Red Flags and Reporting Suspicions SFX has implemented a comprehensive system of red flags to detect potentially suspicious activities. These red flags include:

• • Unusually large transactions or frequent transactions that exceed normal volumes.

  • Rapid movement of funds, including rapid deposits and withdrawals.

  • Significant and sudden changes in transaction types or customer information.

  • Structuring transactions to avoid reporting thresholds.

  • Transactions for unusual purposes or inconsistent explanations.

  • Transactions in round dollar amounts or frequent large cash withdrawals.

  • Transactions involving foreign or offshore jurisdictions.

  • Customers are reluctant to provide requested information or documentation.

11. Amendments to the AML Policy SFX reserves the right to update and amend this AML policy as necessary to ensure ongoing compliance with applicable laws and regulations. All updates will be communicated to employees and stakeholders as appropriate. SFX is dedicated to ensuring the highest level of compliance with AML and CIP requirements to prevent money laundering and terrorist financing activities. Our partnership with Smile ID for digital identity verification strengthens our AML program. We will continue to adapt and enhance our AML procedures as necessary to stay current with evolving regulatory standards and technological advancements.

Contact Information For any inquiries or concerns related to our AML policy, please contact our AML Compliance Person, Martins Chiwenyte Chidume, at [e-mail].

This AML policy was last updated on 10 february, 2025 and is subject to revisions to meet regulatory requirements and industry standards.