ARKBRIDGE ANTI-MONEY LAUNDERING (AML) POLICY

Effective Date: 14/06/2026

1. PURPOSE

OrynthBridge Technologies Ltd (“ArkBridge”, the “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, and 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, and 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.

Customer risk factors may include the client’s identity profile, occupation, source of funds, source of wealth, beneficial ownership, transaction behaviour, and Politically Exposed Person status.

Geographic risk factors may include the client’s country of residence, nationality, the jurisdiction from which funds originate, any connection to sanctioned or high-risk jurisdictions, and countries identified by international authorities as presenting elevated AML or financial crime risks.

Transaction risk factors may include transaction frequency, transaction volume, unusual activity patterns, rapid deposits and withdrawals, and trading activity that is inconsistent with the client’s known profile.

Product risk factors may include leveraged trading products, cryptocurrency-related transactions, cross-border transactions, and high-value transactions.

The Company reserves the right to apply enhanced controls, additional verification measures, or restrictions 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, and client risk classification.

The nature and extent of the verification required will depend on the client’s risk profile, transaction activity, jurisdiction, account structure, and the nature of the business relationship.

5. ENHANCED DUE DILIGENCE (EDD)

Enhanced Due Diligence (“EDD”) may be applied where an elevated level of risk is identified.

EDD may be required in relation to Politically Exposed Persons, high-net-worth clients, high-volume traders, clients connected to high-risk jurisdictions, unusual transaction activity, complex ownership structures, or clients who trigger financial crime indicators.

EDD measures may include additional identification documentation, enhanced source of wealth verification, enhanced source of funds verification, management or senior compliance approval, ongoing monitoring, periodic account reviews, and increased transaction scrutiny.

The Company reserves the right to reject, restrict, suspend, or terminate any customer relationship where the associated risks cannot be satisfactorily understood or mitigated.

6. SANCTIONS COMPLIANCE

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

The Company may screen clients, beneficial owners, authorised representatives, counterparties, and transactions against sanctions lists maintained by the United Nations, the United States Office of Foreign Assets Control (“OFAC”), the European Union, the United Kingdom, and other recognised international or national authorities.

Where sanctions concerns arise, the Company may reject an application, suspend or restrict an account, delay or refuse a transaction, terminate a business relationship, or take any other action considered necessary.

The Company may freeze transactions or assets where required or permitted by applicable law.

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, or assessed by the Company as presenting an unacceptable level of risk.

The Company reserves the right to introduce, amend, or remove jurisdictions from its list of restricted territories at any time.

The use of virtual private networks, proxy services, nominee arrangements, intermediaries, false addresses, or any other method intended to conceal a person’s actual location or circumvent jurisdictional restrictions is strictly prohibited.

8. TRANSACTION MONITORING

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

Monitoring may include deposits, withdrawals, trading behaviour, general account activity, funding patterns, cryptocurrency transfers, cross-border transactions, payment methods, counterparties, and transaction frequency or value.

Monitoring may be conducted manually, automatically, through internal systems, or with the assistance of third-party compliance and transaction-monitoring providers.

9. SUSPICIOUS ACTIVITY INDICATORS

The Company may investigate any activity that it reasonably considers unusual, suspicious, inconsistent with the client’s profile, or potentially connected to financial crime.

Identity-related concerns may include inconsistent personal information, forged or altered documents, identity mismatches, duplicate identities, or information that cannot be independently verified.

Funding-related concerns may include an unexplained source of funds, third-party payments, unusual funding patterns, rapid movement of funds, or frequent account funding and withdrawal cycles without an apparent legitimate purpose.

Trading-related concerns may include activity that is inconsistent with the client’s stated profile, suspicious or coordinated trading patterns, potential market manipulation indicators, abusive trading practices, or the use of trading activity to disguise the movement of funds.

Cryptocurrency-related concerns may include transactions involving mixers or tumblers, darknet exposure, ransomware-linked wallets, sanctioned wallet exposure, high-risk blockchain services, or other adverse blockchain risk indicators.

Geographic concerns may include connections to sanctioned or restricted regions, unexplained activity across multiple jurisdictions, inconsistent location data, or attempts to conceal or bypass geographic restrictions.

10. ACCOUNT RESTRICTIONS

Where compliance or financial crime concerns arise, the Company may request additional information or documentation, delay transactions, restrict account functionality, suspend trading activity, suspend withdrawals, freeze accounts or funds, or terminate the business relationship.

The Company is not obligated to disclose the reason for a compliance review, investigation, restriction, report, or other action where disclosure would be inappropriate, unlawful, or could prejudice the effectiveness of financial crime prevention procedures.

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.

Supporting documentation may include bank statements, salary records, employment records, tax returns, audited financial statements, investment records, inheritance documentation, property sale records, business ownership documentation, transaction agreements, or any other evidence considered appropriate.

Failure to provide evidence that is complete, consistent, verifiable, and satisfactory to the Company may result in transaction delays, account restrictions, refusal of services, or termination of the business relationship.

12. POLITICALLY EXPOSED PERSONS (PEPs)

The Company applies enhanced scrutiny to clients identified as Politically Exposed Persons (“PEPs”), as well as their immediate family members and known close associates where relevant.

Relationships involving PEPs may require senior compliance or management approval, enhanced due diligence, additional source of funds and source of wealth verification, ongoing monitoring, and periodic account reviews.

The Company reserves the right to decline, restrict, or terminate any relationship that presents an unacceptable level of financial crime, corruption, sanctions, or reputational risk.

13. RECORD KEEPING

The Company may retain records relating to customer identification, transaction history, compliance reviews, investigations, sanctions screening, communications, account activity, risk assessments, and financial crime prevention measures.

Records may be retained for the periods required by applicable law, regulatory obligations, dispute resolution requirements, fraud prevention procedures, and financial crime prevention obligations.

Record retention may continue after account closure where legally required or reasonably necessary for compliance, legal, security, or risk management purposes.

14. COOPERATION WITH AUTHORITIES

The Company may cooperate with law enforcement agencies, regulatory authorities, financial intelligence units, courts, government agencies, sanctions authorities, and other competent bodies.

The Company may disclose information, documents, transaction records, account details, or other relevant material where required or permitted by law, or where necessary to comply with legal obligations, prevent financial crime, or protect the integrity and security of the Platform.

15. PROHIBITED ACTIVITIES

The Platform must not be used for money laundering, terrorist financing, sanctions evasion, fraud, bribery, corruption, identity theft, market manipulation, tax evasion, concealment of beneficial ownership, the submission of false or misleading information, or any other unlawful or prohibited purpose.

Any actual or suspected breach of this provision may result in immediate account restriction, suspension, freezing of funds, termination of the business relationship, or reporting to competent authorities where required or permitted.

16. NO LIABILITY FOR COMPLIANCE ACTIONS

To the fullest extent permitted by applicable law, the Company shall not be liable for any loss, delay, restriction, interruption, missed opportunity, or other consequence arising from compliance reviews, AML investigations, sanctions screening, account restrictions, transaction monitoring, regulatory obligations, fraud prevention measures, or cooperation with competent authorities.

Clients acknowledge that such measures may be necessary to protect the Platform, its clients, and the Company, and to comply with applicable legal and compliance obligations.

17. POLICY REVIEW

The Company reserves the right to amend this AML Policy at any time to reflect changes in applicable law, evolving financial crime risks, regulatory developments, operational requirements, changes to the Company’s services, or recognised industry practices.

Any updated version shall become effective upon publication on the Platform or the Company’s website, unless a different effective date is specified.

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.

The Company’s website is https://arkbridge.com, and enquiries may be submitted by email to support@arkbridge.com.