Anti-Money-Laundering & Counter-Terrorist-Financing Policy

BELEM Blockchain Technology Co., Ltd. ("BELEM") is committed to the highest standards of anti-money-laundering (AML) and counter-terrorist-financing (CTF) compliance. As a Money Services Business registered with FINTRAC (registration number M23331281), BELEM maintains a documented compliance programme designed to detect, deter, and report financial crime.

1. Legal framework

Our programme is built to comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations, and is aligned with the standards of the Financial Action Task Force (FATF), the EU Anti-Money-Laundering Directives, and the FATF Travel Rule for virtual asset service providers.

2. The five pillars of our programme

1. Compliance Officer. BELEM has appointed a designated Compliance Officer with authority and independence to administer and enforce the AML/CTF programme.
2. Written policies and procedures. Documented, board- approved policies governing client onboarding, monitoring, reporting, and record-keeping, reviewed and updated regularly.
3. Risk assessment. A documented assessment of money- laundering and terrorist-financing risk across our products, clients, delivery channels, and geographies, with risk-based mitigation.
4. Ongoing training. A continuing training programme for all staff and agents involved in client-facing or transaction-handling roles.
5. Independent review. An effectiveness review of the programme conducted at least once every two years, as required by the PCMLTFA.

3. Governance & senior-management oversight

BELEM's AML/CTF programme is approved by senior management, and, where a board of directors is in place, the board provides oversight of the programme and its performance. Senior management is responsible for setting the compliance culture, allocating sufficient resources — including staffing, technology, and budget — to operate the programme effectively, and ensuring that identified deficiencies are remediated on a timely basis.

4. Compliance Officer responsibilities

The designated Compliance Officer is responsible for the day-to-day operation and integrity of the AML/CTF programme, including:

• Overseeing implementation and ongoing effectiveness of the AML/CTF programme;
• Developing, approving, and maintaining written policies and procedures;
• Reporting regularly to senior management (and the board, where applicable) on the state of compliance;
• Overseeing FINTRAC reporting, including STRs, LVCTRs, LCTRs, and Terrorist Property Reports;
• Monitoring changes in laws, regulations, and regulatory guidance and updating the programme accordingly;
• Coordinating the independent effectiveness review;
• Maintaining and delivering the ongoing AML/CTF training programme.

5. Client identification (KYC) and due diligence

Every client must complete identity verification before transacting. We apply a risk-based approach to customer due diligence (CDD) and enhanced due diligence (EDD) for higher-risk clients, including politically exposed persons (PEPs), heads of international organisations, and their associates. Full document requirements are set out in our KYC & AML Verification policy.

6. Beneficial ownership

For entity clients — corporations, partnerships, trusts, and other legal arrangements — BELEM identifies and verifies the beneficial owners and obtains information on the ownership, control, and structure of the entity. This includes identifying all individuals who directly or indirectly own or control 25% or more of the entity, together with any individual who otherwise exercises control. Where BELEM is unable to obtain or confirm beneficial-ownership information, it takes reasonable measures to ascertain that information, treats the client as higher risk, applies enhanced due diligence, and may decline or terminate the relationship.

7. Third-party determination

BELEM determines whether a person or entity conducting a transaction or opening an account is acting on behalf of a third party. Where a third party is involved, BELEM records the third party's identifying information and the nature of the relationship between the parties, and retains the required third-party determination records in accordance with the PCMLTFA. Where a third-party arrangement cannot be satisfactorily clarified, the relationship is treated as higher risk.

8. Risk-rating methodology

Each client is assigned a risk rating — Low, Medium, or High — based on factors such as client type, geography, products and services used, transaction patterns, delivery channels, and exposure to PEPs or sanctions risk. Higher-risk clients are subject to enhanced controls, including enhanced due diligence, more frequent reviews, and closer transaction monitoring. Risk ratings are reviewed and updated as circumstances change.

9. Ongoing monitoring of business relationships

BELEM conducts ongoing monitoring of all business relationships to detect transactions that must be reported, keep client identification and beneficial-ownership information current, reassess client risk ratings, and ensure that activity remains consistent with the client's known profile and stated purpose. Ongoing monitoring includes:

• Keeping KYC and beneficial-ownership information up to date;
• Periodic reviews performed at a frequency driven by each client's risk rating (higher-risk clients are reviewed more often);
• Monitoring for trigger events — such as material changes in ownership, unusual activity, or adverse media — that prompt an out-of-cycle review;
• Reviewing the overall business relationship, not just individual transactions.

10. Politically exposed persons (PEPs)

In addition to screening at onboarding, BELEM conducts ongoing PEP screening throughout the business relationship. Where a client is determined to be a PEP, a head of an international organisation, a family member, or a close associate, BELEM establishes the source of wealth and source of funds, applies enhanced due diligence and ongoing monitoring, and obtains senior-management approval to open or continue the relationship where required by the PCMLTFA.

11. Sanctions screening

All clients and counterparties are screened at onboarding and on an ongoing basis against consolidated sanctions and watch lists, including those maintained by the United Nations, OFAC (United States), the European Union, HM Treasury (United Kingdom), and Canadian sanctions instruments. BELEM does not onboard or transact with sanctioned persons or residents of sanctioned jurisdictions.

12. Transaction monitoring & blockchain analytics

BELEM applies continuous, risk-based transaction monitoring and uses blockchain analytics tooling to assess the provenance of digital assets, screen wallet addresses, and identify exposure to illicit sources. Transactions that fail risk thresholds are held for manual review.

13. Virtual-asset-specific risks

As a virtual asset service provider, BELEM specifically monitors for the typologies and risks associated with digital assets, including:

• Mixers and tumblers used to obscure the source of funds;
• Privacy coins, where applicable to the assets we support;
• Mule wallets and pass-through addresses;
• Chain hopping across multiple assets to break the audit trail;
• Ransomware-linked and extortion-linked addresses;
• Darknet-market exposure;
• DeFi protocol risks, including unhosted-wallet and smart-contract exposure;
• Cross-chain bridges used to move value between networks.

Wallets and transactions exhibiting these risks are flagged for enhanced review and, where appropriate, held, declined, or reported.

14. Reporting obligations

In accordance with the PCMLTFA, BELEM files the following reports with FINTRAC where applicable:

• Suspicious Transaction Reports (STRs) where there are reasonable grounds to suspect a transaction — completed or attempted — is related to money laundering or terrorist financing.
• Large Cash Transaction Reports (LCTRs) and Large Virtual Currency Transaction Reports (LVCTRs) at or above the prescribed thresholds.
• Terrorist Property Reports where required.
• Reporting in response to a Ministerial Directive issued under the PCMLTFA, where applicable.

Suspicious attempted transactions are reported on the same basis as completed transactions where required under applicable regulations. Where the law requires it, BELEM does not "tip off" clients about reports filed or investigations underway.

15. Record-keeping

BELEM retains client identification, beneficial-ownership, third-party determination, account, and transaction records for a minimum of five years from the end of the client relationship or the date of the transaction, as required under the PCMLTFA.

16. Travel Rule

For qualifying virtual-currency and electronic-funds transfers, BELEM collects, retains, and where required transmits originator and beneficiary information in accordance with the FATF Travel Rule and applicable regulations.

17. Effectiveness testing

BELEM's AML/CTF programme is subject to an independent effectiveness review conducted at least once every two years, or more frequently where required by regulatory changes, findings from prior reviews, or material developments in BELEM's business, products, or risk profile. Findings are reported to senior management and remediated on a tracked, time-bound basis.

18. Prohibited activity

BELEM strictly prohibits the use of its platform for money laundering, terrorist financing, sanctions evasion, fraud, market manipulation, or any other unlawful purpose. We reserve the right to freeze, restrict, or close any account and to decline, hold, or reverse any transaction where required by law or by our risk assessment.

19. Contact the Compliance Officer

Compliance Officer: verification@belem-services.com
General support: Support@belem-services.com