MOON EX LTD.

Purpose
This manual outlines our Know Your Customer (KYC) policies and procedures, designed to prevent money laundering, terrorist financing, and other financial crimes. Compliance with KYC is essential for maintaining the integrity of our platform and protecting our customers.

Scope
This manual applies to all employees involved in customer onboarding, transaction monitoring, and compliance within Moon Ex LTD.

• KYC: Know Your Customer. The process of verifying a customer’s identity and assessing their risk profile.
• AML: Anti-Money Laundering. Procedures to combat financial crimes.
• Beneficial Owner: The individual(s) who ultimately control or benefit from a company or transaction.
• CDD: Customer Due Diligence. The actions taken to collect and verify customer information.
• EDD: Enhanced Due Diligence. Additional scrutiny applied to high-risk customers or transactions.
• PEP: Politically Exposed Person. Individuals holding prominent public positions.

Customer Identification Program (CIP)

• We have a formal CIP requiring the collection of the following information for all customers:
  • Full Legal Name
  • Date of Birth
  • Residential Address (Proof of Address required)
  • Government-Issued Identification (passport, driver’s license, etc.)
  • Source of Funds (for large transactions)

Risk-Based Approach

• Our KYC measures are tiered based on the assessed risk of a customer or transaction. Factors influencing risk levels include:
  • Geographic location
  • Transaction size and frequency
  • Type of activity (deposits, withdrawals, trading)
  • Customer profile (individual vs. corporate entity)

Simplified Due Diligence (SDD)

• May apply to low-risk customers meeting specific criteria (e.g., transaction limits within a given timeframe).

Enhanced Due Diligence (EDD)

• Required for high-risk customers or transactions. This might include:
  • Additional documentation requests
  • In-person verification
  • Source of wealth inquiries

Customer Onboarding

1. Customers provide required information via secure online forms.
2. Identity verification is performed using trusted third-party services and database checks.
3. Risk assessment is conducted based on provided information and other factors.
4. Account approval is given based on successful verification and acceptable risk level.

Ongoing Monitoring

1. Transactions are monitored for suspicious patterns or activity that deviates from a customer’s known profile.
2. Customer information is periodically updated, especially for higher-risk accounts.
3. Potential red flags are investigated, and additional information is requested if needed.

• Record Retention: Customer data and supporting documentation are stored securely for a minimum of 2 years.
• Suspicious Activity Reporting (SAR): Unusual or potentially suspicious transactions are reported promptly to the relevant authorities, in accordance with our requirements.

• All relevant employees receive regular training on KYC procedures and identifying red flags.
• Training is updated as internal policies change.

• We leverage different tech tools to assist with KYC processes, including:
  • Identity verification services
  • Transaction monitoring systems
  • Secure document storage solutions

• This KYC manual is reviewed [annually/semi-annually] or as needed to reflect changes in company policies.