Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) Policy

Last Updated: August 20, 2025

1. 1. Introduction & Policy Statement

   Nommia Global Ltd and its affiliated entities, including Nommia Trade Ltd and its partners ("Nommia," "we," "us"), are fully committed to preventing the use of our financial ecosystem for money laundering, terrorist financing or any other financial crime.

   This Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) Policy outlines the comprehensive framework and procedures we have implemented to ensure compliance with all applicable laws and regulations in the jurisdictions where we operate. This policy applies to all our employees, directors, officers, and, where applicable, our partners and third-party service providers.

   Our commitment is to maintain the highest standards of integrity and diligence to protect our customers, our brand and the financial system.

2. 2. Governing Laws and Regulations

   Nommia's AML/CFT framework is designed in accordance with the legal requirements of the Republic of Cyprus, the European Union, and international best practices. Key governing regulations include:

   • The Prevention and Suppression of Money Laundering and Terrorist Financing Law of Cyprus.
   • The European Union’s 5th and 6th Anti-Money Laundering Directives (AMLD5 & AMLD6).
   • Recommendations issued by the Financial Action Task Force (FATF).
   • Relevant AML/CFT legislation in the jurisdictions of our operational partners, including Saint Lucia and Poland.

3. 3. AML Compliance Officer (MLRO)

   Nommia has appointed a dedicated Money Laundering Reporting Officer (MLRO) who is responsible for the oversight, implementation, and day-to-day management of this AML/CFT Policy. The MLRO has the authority and independence to:

   • Develop and maintain our AML/CFT systems and controls.
   • Serve as the central point of contact for all internal and external AML-related matters.
   • Conduct investigations into suspicious activity.
   • Report suspicious transactions to the relevant Financial Intelligence Units (FIUs), such as Cyprus's Unit for Combating Money Laundering (MOKAS).
   • Ensure that all relevant employees receive appropriate AML/CFT training.

4. 4. Risk-Based Approach (RBA)

   Nommia adopts a Risk-Based Approach to AML/CFT compliance. This means we identify, assess and understand the specific money laundering and terrorist financing risks we face and we apply appropriate measures to mitigate them. Our RBA considers:

   • Customer Risk: The type of customer (individual, corporate), their occupation or business sector, and their country of residence.
   • Geographic Risk: The risks associated with the jurisdictions our customers are from or operate in, with special attention to countries identified as high-risk by the FATF and other bodies.
   • Product/Service Risk: The potential for our products (e.g., CFDs, cryptocurrency exchange) to be used for illicit purposes.

5. 5. Customer Due Diligence (CDD) and KYC Procedures

   We are committed to the principle of "Know Your Customer" (KYC). Robust Customer Due Diligence is performed on all clients before establishing a business relationship. Our CDD measures are tiered based on the assessed risk profile of the customer.

6. 5.1. Standard Due Diligence (CDD)

   At a minimum, we will identify and verify the identity of every customer.

   • For Individual Clients:
     • Full Name
     • Date of Birth
     • Residential Address
     • Nationality
     • Verification: A copy of a valid, government-issued photo ID (e.g., Passport, National ID Card) and a recent Proof of Address document (e.g., utility bill, bank statement dated within the last 3-6 months).
   • For Corporate Clients:
     • Full Legal Name of the Entity
     • Company Registration Number
     • Registered Address and Principal Place of Business
     • Verification: We will obtain corporate documents such as the Certificate of Incorporation, Memorandum and Articles of Association, and identify and verify the identity of all directors and Ultimate Beneficial Owners (UBOs) holding 25% or more of the shares/voting rights, as per the requirements for individual clients.

7. 5.2. Enhanced Due Diligence (EDD)

   Enhanced Due Diligence measures are applied to customers or situations that present a higher risk. This includes, but is not limited to:

   • Politically Exposed Persons (PEPs), their family members, and close associates.
   • Customers from high-risk jurisdictions identified by the FATF.
   • Clients with complex ownership structures where the UBO is not easily identifiable.
   • Unusually large or complex transactions that do not fit the customer's expected profile.

   EDD may involve obtaining additional information on the source of funds/wealth and seeking senior management approval to establish or continue the business relationship.

8. 6. Ongoing Monitoring

   Our AML/CFT obligations do not end after the initial CDD process. We conduct ongoing monitoring of all business relationships and transactions to:

   • Ensure that transactions are consistent with our knowledge of the customer, their business, and their risk profile.
   • Detect and investigate unusual or suspicious activity.
   • Keep customer identification documents and information up-to-date.

   This is achieved through a combination of automated transaction monitoring systems and manual reviews by our compliance team.

9. 7. Reporting of Suspicious Activity

   All Nommia employees are trained to identify and report any activity that they have reasonable grounds to suspect may be related to money laundering or terrorist financing.

   • Internal Reporting: Any suspicious activity must be reported immediately to the MLRO using an internal Suspicious Activity Report (SAR).
   • External Reporting: The MLRO will investigate all internal reports. If the suspicion is substantiated, the MLRO is legally obligated to file a SAR with the relevant Financial Intelligence Unit (FIU) without delay and without tipping off the customer.

10. 8. Record Keeping

    We will retain all records related to customer identification, verification, transaction history, and any AML-related correspondence or reports for a minimum period of five years after the termination of the business relationship, or longer if required by law. These records will be kept confidential and secure.

11. 9. Employee Training

    Nommia provides mandatory AML/CFT training to all relevant employees upon hiring and on an ongoing, annual basis. This training covers:

    • AML/CFT laws and regulations.
    • The contents of this policy and associated procedures.
    • How to identify and report suspicious activity ("red flags").
    • The personal legal obligations of employees.

12. 10. Partner Compliance

    Nommia requires that all its strategic and white-label partners, including Nommia Trade Ltd and P100 LIMITED LIABILITY COMPANY, maintain their own robust AML/CFT policies and procedures that are compliant with the laws of their respective jurisdictions and meet our standards.

13. 11. Policy Review

    This AML/CFT Policy will be reviewed by the MLRO and senior management at least annually, or more frequently if there are significant changes to legislation, our business operations, or the risk landscape.