Latest update: July 16, 2024

1. The EarnPark digital platform is available on the Internet on the website https://earnpark.com/ (the “Platform”), owned and operated by EARNPARK PLATFORM LLP, a Limited Liability Partnership, registered under the laws of the United Kingdom of Great Britain and Northern Ireland, registration number: OC442773, date of formation 22nd of June, 2022, registered at 128 City Road, London, United Kingdom, EC1V 2NX including the website on the Internet, which provides access to the Platform, as well as any services of the Platform.

2. Earnpark Limited, a Company incorporated under the Business Company Act of the British Virgin Islands under BVI registration number 2149760 on the 28th day of May 2024, registered address: Intershore Chambers, Road Town, Tortola, British Virgin Islands, is a subsidiary of EARNPARK PLATFORM LLP with 100% participation of EARNPARK PLATFORM LLP.

are committed to the highest standards of the Anti-Money Laundering (AML) compliance and Anti-Terrorist Financing in accordance with The Money Laundering and Terrorist Financing regulations of British Virgin Islands, requires its management and employees to follow the named standards and actively prevents any actions that aim or facilitate the process of legalizing of illegally gained funds.

This Anti-Money Laundering Compliance and Know your Client Policy (“AML/KYC Policy”, “the/this Policy”) in an effort to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering in any jurisdictions where we conduct business for the purpose of preventing the use of EarnPark’s services by the customers with the aim of money laundering, terrorist financing or other criminal activity.

It is important for us that you understand these rules and policies to the maximum extent possible. Please read this AML/KYC Policy carefully, as it will influence your use of the Platform and the provision of our services. EarnPark identifies and assesses money laundering and financing of terrorism risks based on an overall group-wide understanding of our products and services, transaction types, countries and geographic areas, and user attributes (“Risk-Based Approach”) to implement mitigation measures proportionate with such risks. Further to EarnPark’s compliance commitment, EarnPark conducts constant training regarding its internal policies and relevant regulations throughout the entire organization.

We may amend, update, or replace this AML/KYC Policy from time to time, it is your responsibility to review the Legal and Privacy section on our website from time to time in order to keep apprised of the latest information, practices, and procedures.

EarnPark’s principle is not to enter into business relationships with any criminals and/or terrorists, not to process transactions with results from criminal and/or terrorist activity, and not to facilitate any transactions involving criminal and/or terrorist activity, including the financing of terrorism. EarnPark undertakes to implement all policies and procedures necessary to prevent money laundering and to comply with all applicable legislation in this regard.

Where any issue or matter is not addressed by this AML/KYC Policy, guidance is to be sought from the anti-money laundering legislation referred to above.

By registering as a User and a Customer of the EarnPark, as well as using the Platform, you (“Customer”, “User”, “you”) confirm your acceptance of the Policy.

1.1. The purpose of the Policy is an effective combating of money laundering and terrorist financing) on our website by proper identification of actual users of our Accounts and supervision of their transactions.

1.2. Unless otherwise specified or the context suggests otherwise, all capitalized terms have the meaning given to them in this Policy:

Account: an account created by the User who visited the Website and registered to use the Website.

Website: means a software and hardware complex located at the address: https://earnpark.com/ under the ownership of EarnPark and providing a digital platform for the Customer (user) to carry out the actions provided for by the Agreement.

Platform: means a digital platform provided, owned, and operated by EARNPARK PLATFORM LLP, a Limited Liability Partnership registered in accordance with the laws of the United Kingdom of Great Britain and Northern Ireland, registration number: OC442773, date of formation 22nd of June 2022, registered to the address 128 City Road, London, United Kingdom, EC1V 2NX for access to its services via the Website.

Customer: any person who has registered on the Website and created an Account in order to use the Website and have access to the Platform or who is passing a registration procedure on the Website and creating an Account on the Platform.

Virtual Currency: value represented in digital form, which is digitally transferable, preservable or tradable and which natural persons or legal persons accept as a payment instrument.

Our Services (the “Services”): provide blockchain and crypto access by using certified platform providers.

Business Relationship: a relationship established between EarnPark and its Customers upon the conclusion of an online contract, also referred to as Terms and Conditions, for the provision of the Services.

Compliance Officer: representative appointed by the Management Board or one of the Management Board members responsible for the effectiveness of the Rules, conducting compliance over the adherence to the Rules as well as having the responsibility for reporting and other related tasks.

Money Laundering: the conversion or transfer of property derived from criminal activity or property obtained instead of such property knowing that such property is derived from criminal activity or from an act of participation in such activity for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s actions. The acquisition, possession, or use of property derived from criminal activity or property obtained instead of such property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation therein. The concealment or disguise of the true nature, source, location, disposition, movement, or rights with respect to, or ownership of, property derived from criminal activity or from an act of participation in such an activity. Money laundering also means participation in, association to commit, attempts to commit, and aiding, abetting, facilitating, and counseling the commission of any of the activities referred to in this section. Money laundering is regarded as such also where a criminal activity that generated the property to be laundered was carried out in the territory of another country.

Terrorist Financing: the financing and supporting of an act of terrorism and commissioning thereof.

International Sanctions: list of non-military measures decided by the United Kingdom of Great Britain and Northern Ireland (the UK), British Virgin Islands, the United Nations, or any other International Organization and aimed to maintain or restore peace, prevent conflicts and restore international security, support and reinforce democracy, follow the rule of law, human rights and international law and achieve other objectives of the common foreign and security policy of the UK and British Virgin Islands.

Beneficial Owner: is a natural person who, taking advantage of his/her influence, exercises control over a transaction, operation, or another person and in whose interests or favor or on whose account a transaction or operation is performed taking advantage of his/her influence, makes a transaction, act, action, operation or step or over another person and in whose interests or favor or on whose account a transaction, act, action, operation or step is made. Ultimately owns or controls a legal person through direct or indirect ownership of a sufficient percentage of the shares or voting rights or ownership interest in that person, including through bearer shareholdings or through control via other means. Direct ownership is a manner whereby a natural person holds a shareholding of 25% plus one share or ownership interest of more than 25% in a company. Indirect ownership is a manner of exercising control whereby a company that is under the control of a natural person holds, or multiple companies that are under the control of the same natural person hold a shareholding of 25% plus one share or ownership interest of more than 25% in a company. Holds the position of a senior managing official if, after all, possible means of identification have been exhausted, the person specified herein cannot be identified, and there is no doubt that such person exists or where there are doubts as to whether the identified person is a beneficial owner. In the case of a trust, civil law partnership, community, or legal arrangement, the beneficial owner is the natural person who ultimately controls the association via direct or indirect ownership otherwise and is such association’s settlor or person who has handed over property to the asset pool, trustee or manager or possessor of the property, person ensuring and controlling the preservation of the property, where such person has been appointed, or the beneficiary, or where the beneficiary or beneficiaries have yet to be determined, the class of persons in whose main interest such association is set up or operates.

A politically Exposed Person (“PEP”): is a natural person who is or who has been entrusted with prominent public functions, including a head of state, head of government, minister and deputy or assistant minister; a member of parliament or of a similar legislative body, a member of a governing body of a political party, a member of a supreme court, a member of a court of auditors or of the board of the central bank; an ambassador, a chargé d’affaires and a high-ranking officer in the armed forces; a member of an administrative, management or supervisory body of a state-owned enterprise; a director, a deputy director and member of the board or equivalent function of an international organization, except middle-ranking or more junior officials. The provisions set out herein also include positions in the UK and in other international organizations. A family member of a person performing prominent public functions is the spouse, or a person considered to be equivalent to a spouse, of a politically exposed person; a child and their spouse, or a person considered to be equivalent to a spouse, of a politically exposed person; a parent of a politically exposed person. A close associate of a person performing prominent public functions is a natural person who is known to be the beneficial owner or to have joint beneficial ownership of a legal person or a legal arrangement or any other close business relations with a politically exposed person and a natural person who has sole beneficial ownership of a legal entity or legal arrangement which is known to have been set up for the facto benefit of a politically exposed person.

Restricted Countries: Afghanistan, The Bahamas, Barbados, Botswana, Cambodia, Canada, Crimea, Ghana, Iraq, Iran, Jamaica, Myanmar/Burma, Nicaragua, North Korea, Pakistan, Syria, Trinidad and Tobago, Uganda, Vanuatu, Yemen, Zimbabwe, United States.

The Policy is broadly based on the following legislations:

2.1. It is important to stress that the reporting of your suspicion of money laundering does not constitute a breach of user confidentiality.

2.2. Specific money laundering provisions

In order to facilitate recognition of suspicions of money laundering and reporting of the foregoing to the authorities and so that EarnPark may produce its part of the audit trail to assist in the official investigation. In particular, EarnPark has:

4.1. EarnPark may or may not — at its own discretion and risk assessment — carry out a one-off transaction or form a business relationship in the course of a relevant financial business unless obtains the full name, including any aliases; unique identification number, such as an identity card number, birth certificate number or passport number, or where the user is not a natural person, incorporation number or business registration number; the user’s residential address (or registered address or business address when the user is not a natural person); date of birth (or establishment, incorporation or registration when the user is not a natural person); and nationality (or place of incorporation or place of registration (as may be appropriate).

4.2. For legal persons, EarnPark identifies the natural persons who ultimately own the legal person; ultimately control the legal person; or have ultimate effective control of the legal person. Furthermore, when a user is a legal person, EarnPark identifies the legal form; constitution; powers that regulate and bind the legal person; and the connected parties.

5.1. EarnPark as soon as reasonably practicable after the first contact has been made, and in any event before transferring any money in any currency, that satisfactory evidence is produced or such other measures are taken as will produce satisfactory evidence of the identity of any user. If a user appears to be acting on behalf of another person, identification obligations extend to obtaining sufficient evidence of that third party’s identity.

5.2. Where satisfactory evidence is not supplied, EarnPark will not proceed with any further business and bring to an end any understanding it has reached with the user. If there is knowledge or suspicion of money laundering, it will be reported without delay as provided under these procedures and internal AML Policy.

5.3. EarnPark will make sure that it is dealing with a real person or legal entity, and obtain sufficient evidence to establish that the user is that person or organization. When reliance is being placed on any third party to identify or confirm the identity of any user, the overall legal responsibility to ensure that the procedures and evidence obtained are satisfactory rests with the third party.

5.4. You may only submit your information and your own payment details. EarnPark reserves the right to reject your application to open an account or start an activity when your name is not on the credit or debit card that you present as part of the identification process. EarnPark reserves the right to reject your application to open an account or start to use EarnPark services when your name is not on the documentation that you have provided and/or it deems that it has not accurately identified you as a user.

5.5. As no single form of identification can be fully guaranteed as genuine or representing correct identity, the identification process will need to be cumulative, and no single document or source of data (except for a database constructed from a number of other reliable data sources) must therefore be used to verify both name and permanent address.

5.6. EarnPark will take all required measures, according to applicable laws and regulations issued by regulatory authorities, to establish the identity of its users and, where applicable, their respective beneficial owners.

5.7. If EarnPark deems necessary, in addition to identifying the user, EarnPark may request information regarding the source of wealth, estimated net worth, source of funds to be invested; references or other documentation to corroborate the information, independent background checks through a reputable screening system.

5.8. For individual users, the identity will be established to EarnPark’s satisfaction by reference to official identity papers or such other evidence as may be appropriate under certain circumstances. Information on identity will include, without limitation, full name, date of birth, nationality, complete residential address, e-mail address, and phone number. Identification documents must be current at the time of the submission. Documents used for user identification purposes will typically include a passport, a national identity card, or an equivalent in the relevant jurisdiction; A separate document confirming the residential address (utility bill, bank statement, acknowledgment of address issued by a relevant official).

5.9. Where the applicant is a company, it will be subject to a procedure aimed to identify it and confirm its existence, good standing, and authority of persons acting on its behalf. Documentation required for such purposes may change depending on each particular jurisdiction and will typically include a certificate of incorporation/certificate of trade or the equivalent, evidencing the company is indeed incorporated in a particular jurisdiction under the respective legislation; Certificate of Incumbency or an equivalent document, listing current directors of the company; Statutes, Memorandum, and Articles of Association or equivalent documents confirming the authority of the respective officers of the company to legally bind it and the manner in which this may be done; Extract from the Commercial Register of the country of incorporation may also be used to confirm the aforementioned information if such information is provided in the extract; Share certificates and other supplementary documents that will ascertain beneficial ownership.

5.10. Due diligence must be done on all principal owners identified in accordance with the following principles:

5.11. Natural persons: where a user is an individual, EarnPark shall clearly establish, based on information and documentation provided by the user, whether the user is acting on his/her own behalf.

5.12. Legal entities: where the user is a company, such as a private investment company, EarnPark shall understand the structure of the company, based on information and documentation provided by the user, sufficiently to determine the provider of funds, the principal owner(s) of the shares and those who have control over the funds, e.g. the directors and those with the power to give direction to the directors of the company. With regard to other shareholders, EarnPark will make a reasonable judgment as to the need for further due diligence. This principle applies regardless of whether the share capital is in registered or bearer form.

5.13. While the use of clear scanned versions of documents will be accepted and in case any further clarification is needed, attested scanned copies or original attested copies may be sought for.

5.14. The certifiers may be: - a notary public or another authority with equivalent power to certify copies of documents in the relevant jurisdiction; - a relevant state official (judge, police officer, consular official, etc); or - an authorized financial institution. - If any document regarding the corporate entity (such as an extract from the Commerce Register) is available online through an official website of the relevant state authority, EarnPark may refer to such online version of the document, provided that a printout is made by a staff member of EarnPark and stored in the respective user file.

5.15. EarnPark must identify all Customers who want to use EarnPark’s services and each Customer of EarnPark has to finish a verification procedure.

5.16. All the information and documents provided by the Customer shall be completely clear and readable.

5.17. EarnPark verifies the authenticity of documents and information provided by the Customer and reserves the right to receive additional information about the Customer in case of any doubts concerning the Customer or/and his/her business.

5.18. EarnPark verifies the correctness of the information of the Customer using the information originating from a credible and independent source for that purpose.

5.19. EarnPark may ask for additional information about the Customer in case of any suspicion about the Customer’s identity information or the Customer’s behavior.

5.20. EarnPark may cross-check the Customer through the internal and external databases.

5.21. EarnPark reserves the right to impose additional due diligence requirements to accept Customers residing in certain countries.

5.22. EarnPark reserves the right to suspend any Customer’s transactions if the Customer does not provide the Company with the necessary information.

5.23. EarnPark does not render services to the Сustomers that are on the sanction lists.

5.24. EarnPark does not transact with individuals who are Politically Exposed Persons (PEPs) or their family members.

6.1. EarnPark shall undertake enhanced Due Diligence if there is a higher risk of money laundering or terrorist financing, such as:

6.2. EarnPark must identify what the risks are in every particular case and undertake all appropriate measures to mitigate those risks, such as gathering additional information about the Customer and/or his/her business.

7.1. EarnPark is keeping all records about the Customer and his/her behavior in such a way that it can always be presented to inspectors checking the recorded transactions.

7.2. EarnPark reserves the right to monitor the Customer’s data on an ongoing basis, especially when his identification information was changed, or his activity seemed suspicious (extraordinary for a specific Customer).

7.3. EarnPark reserves the right to request up-to-date documents from the Customers, even if they verified in the past. If the user's identification information was changed or their activity appears suspicious, the Company has the right to request up-to-date documents from the Users, even if they verified in the past.

7.4. The information about the Customer, including the Customer’s transactions, must be stored for no less than one (5) years after termination of the business relationship between the Company and such Customer.

7.5. If a Customer fails to submit all necessary documents and relevant information, or, if based on the documents provided, the Company has a suspicion that money laundering or terrorist financing might be involved, the Company shall not make any transactions with that Customer and shall record as many Customer’s details as possible that will later help to identify the Customer.

8.1. In addition to gathering information from the Customers, EarnPark continues to monitor the activity of every Customer to identify and prevent any suspicious transactions. The Company must investigate every initiated case.

8.2. EarnPark has implemented the system of monitoring the Customer’s transactions (both automatic and, if needed, manual) to prevent using EarnPark’s services for criminal activity.

8.3. EarnPark reserves the right to suspend any Customer’s transactions that can be regarded as illegal or may be related to money laundering or terrorist financing in the opinion of EarnPark’s staff.

8.4. EarnPark implements and maintains internal controls for the purposes of ensuring that all of its operations comply with AML legislation.

9.1. A suspicious transaction will often be one that is inconsistent with a user’s known legitimate business or actions. Emphasis will therefore be placed on knowing the user’s business and his/her requirements and usual transactions. It is the responsibility of all staff to report knowledge or suspicion of money laundering.

The following questions may help to determine whether a transaction is suspicious:

11.1. The Compliance Officer - responsible officer for Compliance with the AML/KYC Policy is an employee of the Company, whose responsibility is to ensure effective compliance with this Policy.

11.2. The responsibility of such a responsible officer is the following methods:

11.3. The responsible officer for Compliance with AML/KYC Policy has the right to interact with law enforcement agencies involved in the prevention of money laundering, terrorist financing and other illegal activities according to the procedure, established by the applicable laws.

13.1. EarnPark may change the Policy from time to time based on the industry standards and applicable laws.

13.2. EarnPark may make such changes at any time without prior notice. Any changes to this Policy may be posted on our Website or sent to the Customer via push notifications or email according to the details specified in the Customer’s Account.

13.3. As such, it is the responsibility of the Customer to check the Company’s Website regularly, to allow the Website to receive such notices, and to keep his/her email address and other account contact information up to date. The Customer agrees to such changes continuing to use the Website and Platform after such changes become effective.

14.1. Internal audit is an independent body that shall test whether the Company has effectively followed the AML\KYC Policy and Procedures, review the compliance of AML\KYC Policy Procedure, conduct checks and reviews to ensure that the control and monitoring and reporting procedures under this Policy are followed. This also involves examining the policies and procedures that govern the identification, verification, and monitoring of customers, as well as the detection and reporting of suspicious activities.

14.2. Internal audit should be done at least annually by independent, reliable, and professional providers of the Company’s choice.