Anti-Money Laundering (AML) Policy

At Monkey Tilt, we are committed to maintaining the highest standards of integrity and compliance with all applicable laws and regulations. This Anti-Money Laundering (AML) Policy is designed to prevent money laundering and terrorist financing activities on our platform. We take a proactive approach to detect, deter, and report any suspicious activities.

Objectives of the AML Policy

• Prevent Money Laundering: Implement measures to prevent the use of our platform for money laundering activities.
• Compliance: Ensure compliance with relevant laws, regulations, and guidelines.
• Detection and Reporting: Detect and report suspicious activities to the appropriate authorities.
• Education and Training: Educate and train our employees on AML requirements and procedures.

Key Components of the AML Policy

Component	Description
Customer Due Diligence (CDD)	Verify the identity of our customers and assess the risk they pose.
Transaction Monitoring	Continuously monitor transactions to detect suspicious activities.
Record Keeping	Maintain records of transactions and customer information for a specified period.
Reporting	Report suspicious activities to the relevant authorities.
Employee Training	Provide ongoing training to employees on AML policies and procedures.

Customer Due Diligence (CDD)

Customer Due Diligence is a critical component of our AML policy. It involves verifying the identity of our customers and assessing the risks associated with them. We follow a risk-based approach to CDD, which includes:

• Identification: Collecting and verifying customer information such as name, date of birth, address, and identification documents.
• Risk Assessment: Assessing the risk profile of each customer based on factors such as geographic location, type of transactions, and source of funds.
• Ongoing Monitoring: Continuously monitoring customer activities to ensure they align with their risk profile.

Transaction Monitoring

We employ sophisticated monitoring systems to detect unusual or suspicious transactions. Our transaction monitoring process includes:

• Automated Alerts: Using automated systems to generate alerts for transactions that deviate from normal patterns.
• Manual Review: Conducting manual reviews of flagged transactions to determine if they are suspicious.
• Investigation: Investigating suspicious transactions and gathering additional information as needed.

Record Keeping

We maintain comprehensive records of all transactions and customer information to comply with legal and regulatory requirements. Our record-keeping practices include:

Record Type	Retention Period
Customer Identification Records	Minimum 5 years
Transaction Records	Minimum 5 years
Suspicious Activity Reports	Minimum 5 years
Employee Training Records	Minimum 5 years

Reporting Suspicious Activities

We are committed to reporting any suspicious activities to the relevant authorities promptly. Our reporting process includes:

• Internal Reporting: Employees are required to report any suspicious activities to the AML Compliance Officer.
• External Reporting: The AML Compliance Officer will review and, if necessary, report the suspicious activities to the appropriate authorities.

Employee Training

We provide ongoing training to our employees to ensure they understand and comply with our AML policies and procedures. Our training program includes:

• Initial Training: Comprehensive training for new employees on AML policies and procedures.
• Ongoing Training: Regular updates and refresher courses to keep employees informed of any changes in AML regulations and best practices.
• Specialized Training: Additional training for employees in high-risk areas or roles.

Roles and Responsibilities

Role	Responsibilities
Board of Directors	Oversee the implementation and effectiveness of the AML policy.
AML Compliance Officer	Develop, implement, and monitor the AML policy; report suspicious activities.
Employees	Comply with AML policies and procedures; report any suspicious activities.

Monkey Tilt is dedicated to preventing money laundering and terrorist financing activities on our platform. Our comprehensive AML policy ensures that we comply with all relevant laws and regulations while maintaining the highest standards of integrity. For any questions or further information about our AML policy, please contact our AML Compliance Officer.

By adhering to this policy, we aim to provide a safe and secure environment for all our customers and stakeholders.