Anti-Money Laundering and Counter-Terrorist Financing  Policy and Procedures

Updated 03/29/2023

This document outlines the Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) policy and procedures for BixBeta Inc. The purpose of this policy is to ensure that our company remains in full compliance with all applicable AML and CTF laws and regulations, and to prevent our organization from being used to facilitate money laundering or terrorist financing activities.

1. Scope
This policy applies to all employees, directors, officers, and agents of BixBeta and covers all activities, products, and services offered by the company.

2. Definitions
Money Laundering: The process of concealing the origins, ownership, or destination of illegally obtained funds, typically by passing them through legitimate financial systems or businesses. Terrorist Financing: The provision or collection of funds, by any means, directly or indirectly, with the intention or knowledge that they will be used to carry out acts of terrorism or to support terrorist organizations.

3. AML and CTF Compliance Officer
BixBeta will appoint an AML and CTF Compliance Officer who will be responsible for the development, implementation, and ongoing maintenance of the company's AML and CTF policies and procedures. The Compliance Officer will also ensure that all employees receive appropriate training on these policies and will be responsible for monitoring compliance within
the organization.

4. Customer Due Diligence (CDD)
BixBeta will establish and maintain a risk-based CDD program to identify, assess, and monitor the risk associated with each customer relationship. The CDD program will include:

a. Customer identification and verification: All new customers will be required to provide identification information, such as their name, address, date of birth, and a government-issue identification number. BixBeta will take reasonable steps to verify the identity of each customer using reliable, independent sources.

b. Beneficial ownership information: For legal entities, BixBeta will collect information on beneficial owners who own or control more than a specified percentage of the entity, as defined by applicable regulations.

c. Ongoing monitoring: BixBeta will regularly review customer information and transactions to
ensure that the customer's risk profile remains accurate and up-to-date. Any changes in a
customer's risk profile will be documented and appropriate action will be taken.

5. Suspicious Activity Reporting
All employees of BixBeta are required to report any suspicious activity or transactions to the AML and CTF Compliance Officer. The Compliance Officer will investigate the reported activity and, if necessary, file a Suspicious Activity Report (SAR) with the relevant authorities.

6. Recordkeeping
BixBeta will maintain records of all customer identification documents, transaction records, and any other relevant documents for a period of at least five years from the date of the transaction or the end of the customer relationship, as required by applicable laws and regulations.

7. Training
All employees of BixBeta will receive AML and CTF training upon joining the company and will be required to complete ongoing training at least annually. The training will cover relevant laws and regulations, the risks associated with money laundering and terrorist financing, and the company's policies and procedures for detecting and reporting suspicious activity.

8. Auditing and Review
BixBeta will conduct periodic internal and external audits to ensure compliance with AML and CTF laws, regulations, and the company's policies and procedures. The results of these audits will be used to identify areas for improvement and to update our policies and procedures as needed.

9. Sanctions Compliance
BixBeta will maintain a sanctions compliance program to ensure that the company does not engage in any business activities with individuals, entities, or countries subject to sanctions imposed by relevant authorities, such as the United Nations, the European Union, or the United States Office of Foreign Assets Control (OFAC). The sanctions compliance program will include:

a. Screening: BixBeta will screen all new and existing customers, suppliers, and business partners against applicable sanctions lists to ensure that the company does not engage in transactions or dealings with sanctioned individuals or entities.

b. Ongoing monitoring: BixBeta will regularly update its sanctions screening process to account for any changes in applicable sanctions lists and will conduct ongoing monitoring of customer and transaction data to identify potential sanctions violations.

c. Reporting: If a potential match with a sanctioned individual or entity is identified, BixBeta will report the information to the AML and CTF Compliance Officer, who will conduct a further investigation and, if necessary, report the potential violation to the appropriate authorities.

10. Penalties for Non-Compliance
Non-compliance with this AML and CTF policy and procedures may result in disciplinary action, up to and including termination of employment or termination of the business relationship with BixBeta. Additionally, non-compliance with AML and CTF laws and regulations can lead to severe legal and financial penalties, reputational damage, and the potential loss of business licenses or authorizations.

11. Policy Review and Updates
BixBeta will regularly review and update this AML and CTF policy and procedures to ensure that they remain in line with current laws, regulations, and industry best practices. All employees, directors, officers, and agents of the company will be informed of any changes to the policy and will be expected to comply with the updated policy.

BixBeta is committed to maintaining a robust AML and CTF compliance program to protect our organization, our customers, and the financial system from the risks associated with money laundering and terrorist financing. By adhering to this policy and its associated procedures, we can ensure that we continue to operate in a responsible and compliant manner.

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