Anti-Money Laundering Policy

EXBORA is committed to preventing money laundering and any activity that facilitates money laundering or funding of terrorist or criminal activities. We implement procedures to detect and prevent money laundering activities, including:

• Verification of customer identity
• Monitoring of suspicious transactions
• Risk assessment procedures
• Record keeping requirements
• Regular staff training

Our KYC procedures require all users to:

• Provide valid government-issued identification
• Submit proof of residence
• Complete verification procedures
• Update information when requested
• Declare source of funds when required

Additional verification may be required based on transaction volume or risk assessment.

We monitor transactions for suspicious activities including:

• Unusual transaction patterns
• High-risk jurisdiction transfers
• Large volume transactions
• Multiple accounts linked to same user
• Structured transactions below reporting thresholds

Our risk assessment framework considers:

• Customer risk profiles
• Geographic risk factors
• Transaction patterns
• Product and service risks
• Delivery channel risks

Risk levels determine the extent of due diligence measures applied.

We strictly prohibit:

• Money laundering activities
• Terrorist financing
• Fraudulent transactions
• Anonymous accounts
• Transactions with shell banks

Violations will result in immediate account termination and reporting to authorities.

We comply with reporting requirements including:

• Suspicious activity reports (SARs)
• Currency transaction reports
• Regulatory compliance reports
• Law enforcement requests
• International cooperation requests

We maintain records of:

• Customer identification documents
• Transaction histories
• Due diligence reports
• Suspicious activity reports
• Training records

Records are kept for a minimum of 5 years or as required by law.

Our AML training program includes:

• Regular compliance training
• Updates on regulatory changes
• Suspicious activity identification
• Reporting procedures
• Customer due diligence requirements

Our Compliance Officer is responsible for:

• Implementing AML procedures
• Monitoring compliance
• Reviewing suspicious activities
• Updating policies and procedures
• Liaising with authorities

This policy is reviewed and updated:

• Annually at minimum
• When regulations change
• After risk assessment updates
• Following audit recommendations
• As needed for compliance

Users will be notified of significant policy changes.