Anti-Money Laundering & Counter-Terrorism Financing (AML/CTF) Policy

1. Purpose

This policy sets out the framework through which Coinsend Technologies Ltd (“Coinsend”, “the Company”) identifies, assesses, monitors, and mitigates the risk of money laundering (ML) and terrorism financing (TF) arising from its business of facilitating the conversion of customers' crypto assets into fiat currency. It is intended to ensure compliance with applicable Kenyan law, including the Proceeds of Crime and Anti-Money Laundering Act (POCAMLA), the Virtual Asset Service Providers Act, 2025, and the Virtual Asset Service Providers Regulations, 2026, as well as international standards issued by the Financial Action Task Force (FATF).

2. Scope

This policy applies to all directors, employees, contractors, and agents of Coinsend, and to all customer relationships and transactions processed through the Company's platform, regardless of transaction size.

3. Designated Compliance Officer

The Company has designated the following individual as its Compliance Officer, responsible for overseeing and coordinating the AML/CTF programme:

• Name: Brian Mumo Muthoki
• Role: Director & Compliance Officer
• Responsibilities: Policy implementation, staff training, transaction monitoring oversight, suspicious activity reporting, and liaison with regulators (including the Central Bank of Kenya).

4. Risk-Based Approach

Coinsend applies a risk-based approach to customer relationships, assessing ML/TF risk according to factors including customer type, transaction volume and pattern, geographic exposure, and source of funds. Customers are categorised into risk tiers (Low, Medium, High), with the level of due diligence applied scaled accordingly.

5. Customer Due Diligence (CDD)

Before onboarding, Coinsend verifies the identity of every customer using government-issued identification and, where applicable, proof of address. CDD includes:

• Identity verification against a valid national ID, passport, or equivalent document
• Screening against sanctions lists (UN, OFAC, and applicable Kenyan lists) and Politically Exposed Persons (PEP) databases
• Assessment of the customer's source of funds for higher-value or higher-risk transactions
• Ongoing monitoring of the customer relationship for changes in risk profile

6. Enhanced Due Diligence (EDD)

Customers assessed as higher-risk — including PEPs, customers transacting large volumes, or those linked to higher-risk jurisdictions — are subject to Enhanced Due Diligence, including additional identity verification, source-of-funds documentation, and more frequent transaction review.

7. Transaction Monitoring & Reporting

Coinsend monitors customer transactions for patterns indicative of money laundering or terrorism financing, including unusually large or rapid conversions, structuring, and transactions involving high-risk wallets or jurisdictions. Where a transaction or pattern of activity is deemed suspicious, the Compliance Officer will file a Suspicious Transaction Report (STR) with the Financial Reporting Centre (FRC) of Kenya in accordance with POCAMLA.

8. Record-Keeping

Coinsend retains all customer identification records, transaction records, and supporting documentation for a minimum of seven (7) years from the date the transaction was completed or the business relationship ended, in line with Kenyan record-keeping requirements. Records are stored securely with access restricted to authorised personnel.

9. Sanctions Compliance

Coinsend screens all customers and transactions against applicable sanctions regimes, including United Nations Security Council sanctions lists, OFAC (U.S. Treasury) sanctions lists, and any sanctions lists issued by Kenyan authorities. The Company will not process transactions for individuals or entities identified on these lists.

10. Staff Training

All personnel involved in customer onboarding, transaction processing, or compliance functions will receive training on AML/CTF obligations, red flags for suspicious activity, and internal reporting procedures prior to taking on such responsibilities, and periodically thereafter as the Company grows.

11. Internal Controls & Review

The Compliance Officer will review this policy and the Company's AML/CTF controls at least annually, or sooner if there is a material change in the Company's business, customer base, or applicable law. Internal controls include dual authorisation for high-risk transactions and periodic self-review of onboarding and monitoring records by the Compliance Officer.

12. Regulatory Status

Coinsend acknowledges that virtual-asset-to-fiat conversion services fall under the supervisory authority of the Central Bank of Kenya (CBK) pursuant to the Virtual Asset Service Providers Act, 2025 and Virtual Asset Service Providers Regulations, 2026. The Company is in the process of determining and pursuing the applicable licensing/authorisation requirements with the CBK.

13. Approval

This policy has been reviewed and adopted by the Company's director(s).