AML Policy

EGE MONEY INVESTMENT YAZILIM A.Ş. ANTI-MONEY LAUNDERING (AML) POLICY

Money laundering is the cover-up of illegal resources by turning them into cash or seemingly legitimate investments.

As Ege Money Investment Yazılım A.Ş (briefly referred to as "Ege Money"), we attach importance to the security of our customers' accounts. We apply the AML (Money Laundering) policy in order to prevent money laundering in any way. In this context, the Money Laundering Policy (hereinafter referred to as "AML Policy") summarizes the procedures and mechanisms determined by Ege Money to prevent money laundering.

The purpose of the Anti-Money Laundering Policy is; With a risk-based approach, the Law on Prevention of Laundering Proceeds of Crime No. 5549, and raising awareness of employees about the prevention of money laundering and terrorism financing by evaluating customers, transactions, and services within Ege Money Investment Yazılım A.Ş. It is the notification to the customers that it has been carried out by the legislation in force, especially Law No. 6415 on the Prevention of Financing of Terrorism.

Within the scope of this AML Policy, customers whose AML policy is operated in order not to harm the Company's activities, the real person who is a member of the platform ("Platform") accessed from www.egemoney.com and who benefits from the services offered on the Platform and accepts the provisions of this AML Policy expresses.

Ege Money has regulated its AML Policy under international legal norms and standards and applicable legislation, implicitly verifying the identity of all customers to a reasonable level, applying a risk-based approach to monitoring customer transactions, any suspicious transactions carried out by customers. It has taken many measures such as notifying the relevant institutions and organizations within the framework of the current legislation and recording the transactions, ensuring the necessary organization to coordinate the execution and applicability of the AML Policy before the company.

Accordingly, Ege Money follows the following policies:

1) Accordingly, Ege Money follows the following policies:

· Not working with criminals and/or terrorists;

· Failing to process transactions resulting from criminal and/or terrorist activities;

· Failing to facilitate any action related to crime and/or terrorist activities.

Risk assessment

2) Risk assessment

Ege Money adopts a risk-based approach to money laundering and financing of terrorism, in line with both national and international requirements. Thus, measures to prevent money laundering and financing terrorism are proportionate to the risks identified and allow resources to be effectively devoted. Resources are used on a priority basis and the greatest attention is paid to the greatest risks.

Since Ege Money adopts a risk-based approach in monitoring the financial activities of its customers, to prevent money laundering and financing of terrorism, it can perform risk analysis with the following methods and take the relevant Customers to monitor within the framework of the information obtained as a result of the risk analysis.

Customers and transactions in the high-risk group are as follows:

· If the total amount of a single cryptocurrency purchase-sale transaction or multiple linked transactions is equal to or more than 500,000 TL;

· If the total amount of a single cryptocurrency swap transaction or multiple linked transactions is equal to or more than 500,000 TL;

· In cases requiring suspicious transaction reporting within the framework of current legislation;

· In case of doubt about the accuracy and adequacy of previously acquired credentials;

· If a third party performs complex transactions that have the potential to hide the beneficiaries;

· In cases where money resources cannot be easily verified;

· Unusual transactions with any economic or visible legitimate purpose.

Process Monitoring

3) Process Monitoring

Monitoring customer transactions and analyzing the data obtained are also important tools for risk assessment and detection of suspicious transactions. If there is a suspicion of money laundering, Ege Money monitoring all transactions (Customers in high-risk group and transactions, Complex and unusual transactions, transactions with high-risk countries, customer information and documents, written and mandatory information to be kept regarding crypto money trading and transfer, whether a transaction performed by the customer is following the information about the transaction in question, etc.) and has the right to:

· Reporting suspicious transactions to the relevant law enforcement units;

· Requesting the customer to provide additional information and documents;

· Suspension or closure of the client account;

The list above is not exhaustive, and the AML Policy Compliance Officer monitors customers' transactions daily to report customers and determine whether they will consider them suspicious.

Know Your Customer Policy,

4) Know Your Customer Policy,

The Know-Your-Customer Policy can be accessed through our www.egemoney.com site.

Verification Procedure

5) Verification Procedure

5.1 Ege Money will establish its own procedures to determine anti-money laundering standards and compliance with Know Your Customer (KYC) policy.

5.2 Ege Money, its customers complete a verification procedure. Ege Money reserves the right to collect the identity information of its customers for the purposes of AML policy. This information is processed in accordance with Ege Money Privacy Policy and stored securely.

5.3 Ege Money can request a second Customer identification document: (A bank receipt not longer than 3 months or electricity / water bill, which includes the customer's full name and real address)

5.4 Ege Money reserves the right to request additional information about Customers identified as dangerous or suspicious after confirming the accuracy of the documents and information submitted by the customers.

5.5 If the customer's identity information has been changed or its activities are found to be suspicious, Ege Money has the right to request updated documents from the Customer, even if their identity has been verified in the past.

Reporting

6) Reporting

Within the scope of the services provided by Ege Money, in cases that raise suspicion about money laundering and the financing of terrorism, the Financial Crimes Investigation Board is notified to the Financial Crimes Investigation Board in accordance with the current legislation, regardless of the amount of transactions determined as suspicious transactions as a result of the necessary investigations. The real persons who carry out the suspicious transaction and their legal representatives, the managers and personnel who do not comply with the obligation to report the suspicious transaction will be responsible for all kinds of legal, administrative and criminal sanctions.

Anti-Money Laundering Officer

7) Anti-Money Laundering Officer

The Anti-Money Laundering Officer is an employee of Ege Money who is responsible for ensuring compliance with the AML Policy. The Anti-Money Laundering Officer has been tasked with the following issues:

· Collection of customers' identification information;

· Establishing and updating internal policies and procedures for creating, reviewing, submitting and storing all necessary reports in accordance with existing laws and regulations;

· To monitor and analyze significant deviations from customers' extraordinary activities;

· Implementing a records management system for recording and retrieving documents, files, forms and log session inputs and outputs;

· Regularly updating risk assessments;

Training, Updating and Internal Audit

8) Training, Updating and Internal Audit

Ege Money fulfills all its obligations within the scope of training with the personnel policy and procedures it has issued in accordance with the current legislation. In this context, it provides many trainings to its personnel, especially the Anti-Money Laundering Procedure, and ensures that this information is kept up-to-date.

Ege Money periodically audits whether its activities related to the "Law Against Money Laundering and Terrorism Financing", regulations and communiqués comply with the current legislation, Company policies and procedures.