(KYC) Policy and Procedure

1. Purpose and Commitment

This policy outlines FXAR Global Ltd’s commitment to preventing money laundering, terrorist financing, and all forms of financial crime within its operations and business relationships. Money laundering refers to the process of disguising the proceeds of criminal activity to conceal their illegal origin. Terrorist financing refers to the provision or collection of funds to support individuals or organisations engaged in terrorism. FXAR Global Ltd is committed to maintaining robust systems and controls to detect, prevent, and report such activities in compliance with applicable laws including the UK Money Laundering Regulations 2017, Proceeds of Crime Act 2002, and FATF recommendations.

2. Policy Oversight

The Compliance Department is responsible for the development, implementation, and ongoing review of this AML & KYC policy and all supporting procedures. FXAR Global Ltd commits to reviewing this policy annually or sooner where legal or operational changes require it.

3. Scope

This policy applies to all areas of SinTree’s operations, including performers, studios, fans, suppliers, and all business partners, as well as staff and agents of FXAR Global Ltd.

4. Know Your Counterparty (KYC) Procedures

FXAR Global Ltd has implemented structured KYC processes to identify, verify, and assess the legitimacy of all counterparties (business partners, suppliers, studios, and creators). All counterparties must complete the KYC Verification Form and upload supporting documents before engaging in financial transactions. Verification includes collecting company information, validating identity documents, confirming beneficial ownership, and screening against FATF, OFSI, UN, EU, and PEP lists.

5. Risk-Based Approach

Each counterparty is assigned a risk rating based on geography, business type, and transaction profile. Enhanced Due Diligence (EDD) is applied for higher-risk relationships. Where risk indicators are identified, FXAR Global Ltd may cease trading, identify beneficial owners, conduct site inspections, or request additional documentation.

6. Record-Keeping and Monitoring

FXAR Global Ltd maintains KYC and transaction records for at least five years. Records include identity documents, payment history, and transactions exceeding €10,000. Suspicious transactions are escalated to the MLRO and, if necessary, reported to the UK National Crime Agency (NCA) via a Suspicious Activity Report (SAR).

7. Performer Verification & Approval

SinTree verifies all performers before their content becomes public. Performers must upload a government-issued ID, proof of address, and a live selfie holding their ID. Verification is completed through Yoti or equivalent systems. Performers and studios cannot publish or stream content until full verification and approval by the compliance team.

8. Ongoing Monitoring & Review

All users and counterparties are monitored for suspicious activity such as unusual transactions, mismatched data, or false KYC attempts. Suspicious accounts are immediately suspended pending investigation.

9. Staff Training & Awareness

All relevant employees and contractors receive annual training on AML/KYC procedures, red flag indicators, and reporting obligations.

10. Contact

Compliance Department – FXAR Global Ltd (SinTree)

■ compliance@sintree.net

Registered Office: 124 City Road, London, England, EC1V 2NX

11. Company Information

FXAR Global Ltd (Trading as SinTree)

Company Number: 16427001

Registered Office: 124 City Road, London, England, EC1V 2NX