ARKBRIDGE ANTI-MONEY LAUNDERING (AML) POLICY

Effective Date: 14/06/2026

1. PURPOSE

OrynthBridge Technologies Ltd ("ArkBridge", "Company", "we", "our", or "us") is committed to maintaining a comprehensive Anti-Money Laundering ("AML"), Counter-Terrorist Financing ("CTF"), Counter-Proliferation Financing ("CPF"), and financial crime prevention framework.

This AML Policy establishes the principles, controls, and procedures implemented by the Company to prevent the misuse of its services for unlawful purposes, including:

• money laundering;

• terrorist financing;

• sanctions evasion;

• fraud;

• corruption;

• bribery;

• tax evasion;

• identity theft;

• cyber-enabled financial crime;

• proliferation financing;

• other illicit activities.

The Company adopts a risk-based approach designed to align with internationally recognised AML and financial crime prevention principles and industry best practices.

2. POLICY OBJECTIVES

The objectives of this Policy are to:

• prevent the Platform from being used for financial crime;

• identify and verify customers appropriately;

• monitor transactions and account activity;

• identify suspicious behaviour;

• comply with applicable legal obligations;

• maintain robust sanctions controls;

• protect clients and the integrity of the Platform;

• support law enforcement and regulatory authorities where legally required.

3. RISK-BASED APPROACH

ArkBridge applies a risk-based methodology when assessing customers, transactions, products, services, and jurisdictions.

Risk factors considered may include:

Customer Risk

• identity profile;

• occupation;

• source of funds;

• source of wealth;

• beneficial ownership;

• transaction behaviour;

• PEP status.

Geographic Risk

• country of residence;

• nationality;

• funding source jurisdiction;

• sanctioned jurisdictions;

• high-risk jurisdictions;

• countries identified by international authorities as presenting elevated AML risks.

Transaction Risk

• transaction frequency;

• transaction volume;

• unusual activity patterns;

• rapid deposits and withdrawals;

• inconsistent trading activity.

Product Risk

• leveraged trading products;

• cryptocurrency-related transactions;

• cross-border transactions;

• high-value transactions.

The Company reserves the right to impose enhanced controls where elevated risk is identified.

4. CUSTOMER DUE DILIGENCE (CDD)

The Company conducts Customer Due Diligence ("CDD") procedures before, during, and after the establishment of a business relationship.

CDD measures may include:

• identity verification;

• proof of address verification;

• beneficial ownership verification;

• source of funds verification;

• source of wealth verification;

• sanctions screening;

• adverse media screening;

• risk classification.

The extent of verification required will depend on the client's risk profile and the nature of the relationship.

5. ENHANCED DUE DILIGENCE (EDD)

Enhanced Due Diligence may be applied where elevated risk is identified.

EDD may be required for:

• Politically Exposed Persons (PEPs);

• high-net-worth clients;

• high-volume traders;

• high-risk jurisdictions;

• unusual transaction activity;

• complex ownership structures;

• clients triggering financial crime indicators.

EDD measures may include:

• additional identification documentation;

• enhanced source of wealth verification;

• enhanced source of funds verification;

• management approval;

• ongoing monitoring;

• increased transaction scrutiny.

The Company reserves the right to reject any customer relationship where risks cannot be satisfactorily mitigated.

6. SANCTIONS COMPLIANCE

ArkBridge maintains sanctions compliance controls designed to prevent access to the Platform by prohibited individuals, entities, organisations, or jurisdictions.

The Company may screen against sanctions lists maintained by:

• United Nations;

• OFAC;

• European Union;

• United Kingdom;

• other recognised international authorities.

The Company may reject, suspend, restrict, or terminate accounts where sanctions concerns arise.

The Company may freeze transactions or assets where legally required.

7. RESTRICTED JURISDICTIONS

The Company does not provide services to individuals or entities located in jurisdictions that are:

• subject to comprehensive sanctions;

• prohibited by applicable law;

• identified as unacceptable risk by the Company.

The Company reserves the right to modify its list of restricted jurisdictions at any time.

Use of VPNs, proxies, nominee arrangements, intermediaries, or other methods intended to circumvent jurisdictional restrictions is strictly prohibited.

8. TRANSACTION MONITORING

ArkBridge maintains systems and procedures designed to monitor customer activity and identify unusual, suspicious, or potentially unlawful conduct.

Monitoring may include:

• deposits;

• withdrawals;

• trading behaviour;

• account activity;

• funding patterns;

• cryptocurrency transfers;

• cross-border transactions.

Monitoring may be conducted manually, automatically, or through third-party compliance systems.

9. SUSPICIOUS ACTIVITY INDICATORS

Examples of activity that may trigger review include:

Identity Concerns

• inconsistent personal information;

• forged documentation;

• identity mismatches;

• unverifiable information.

Funding Concerns

• unexplained source of funds;

• third-party payments;

• unusual funding patterns;

• frequent account funding and withdrawal cycles.

Trading Concerns

• activity inconsistent with customer profile;

• suspicious trading patterns;

• market manipulation indicators;

• abusive trading practices.

Cryptocurrency Concerns

• transfers involving mixers or tumblers;

• darknet exposure;

• ransomware-linked wallets;

• sanctioned wallet exposure;

• blockchain risk indicators.

Geographic Concerns

• connections to sanctioned regions;

• unexplained jurisdictional activity;

• attempts to bypass restrictions.

The Company may investigate any activity it reasonably considers unusual or suspicious.

10. ACCOUNT RESTRICTIONS

Where concerns arise, the Company may take action including:

• requesting additional information;

• delaying transactions;

• restricting account functionality;

• suspending trading activity;

• suspending withdrawals;

• freezing accounts;

• terminating business relationships.

The Company is not obligated to disclose the basis of compliance reviews where doing so would be inappropriate or prohibited by law.

11. SOURCE OF FUNDS AND SOURCE OF WEALTH

The Company may require customers to demonstrate the legitimate origin of funds or wealth used in connection with the Platform.

Documentation may include:

• bank statements;

• salary records;

• tax returns;

• audited financial statements;

• investment records;

• inheritance documentation;

• property sale records;

• business ownership documentation.

Failure to provide satisfactory evidence may result in restrictions or termination.

12. POLITICALLY EXPOSED PERSONS (PEPs)

The Company applies enhanced scrutiny to clients identified as Politically Exposed Persons.

PEP relationships may require:

• senior compliance approval;

• enhanced due diligence;

• ongoing monitoring;

• periodic reviews.

The Company reserves the right to decline relationships presenting elevated financial crime risk.

13. RECORD KEEPING

The Company may retain records relating to:

• customer identification;

• transaction history;

• compliance reviews;

• investigations;

• sanctions screening;

• communications;

• financial crime assessments.

Records may be retained for periods required by:

• applicable law;

• regulatory obligations;

• dispute resolution requirements;

• financial crime prevention obligations.

Retention may continue after account closure.

14. COOPERATION WITH AUTHORITIES

The Company may cooperate with:

• law enforcement agencies;

• regulatory authorities;

• financial intelligence units;

• courts;

• government agencies;

• sanctions authorities.

The Company may disclose information where required by law or where necessary to protect the integrity of the Platform and comply with legal obligations.

15. PROHIBITED ACTIVITIES

The following activities are strictly prohibited:

• money laundering;

• terrorist financing;

• sanctions evasion;

• fraud;

• bribery;

• corruption;

• identity theft;

• market manipulation;

• use of false information;

• concealment of beneficial ownership;

• use of the Platform for unlawful purposes.

Any violation may result in immediate account suspension or termination.

16. NO LIABILITY FOR COMPLIANCE ACTIONS

The Company shall not be liable for losses, delays, restrictions, or interruptions resulting from:

• compliance reviews;

• AML investigations;

• sanctions screening;

• account restrictions;

• regulatory obligations;

• fraud prevention measures.

Clients acknowledge that such measures are necessary to protect the Platform and comply with applicable obligations.

17. POLICY REVIEW

The Company reserves the right to amend this AML Policy at any time to reflect:

• changes in law;

• evolving financial crime risks;

• regulatory developments;

• operational requirements;

• industry best practices.

Updated versions shall become effective upon publication on the Platform.

18. CONTACT INFORMATION

Questions relating to this AML Policy may be directed to:

OrynthBridge Technologies Ltd
Registration No. 137061
Trust Company Complex, Ajeltake Road
Ajeltake Island, Majuro
Marshall Islands MH96960

Website: https://arkbridge.com
Email: support@arkbridge.com