Anti-Money Laundering (AML) Policy for Airvolt Inc.

It is the policy of the firm to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Bank Secrecy Act (BSA) and its implementing regulations. Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. Although cash is rarely deposited into securities accounts, the securities industry is unique in that it can be used to launder funds obtained elsewhere, and to generate illicit funds within the industry itself through fraudulent activities. Examples of types of fraudulent activities include insider trading, market manipulation, ponzi schemes, cybercrime and other investment-related fraudulent activity. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex. Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable BSA regulations and FINRA rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

1. Purpose: The purpose of this AML Policy is to prevent and detect money laundering and terrorist financing activities within Airvolt Inc. This policy outlines the measures and controls to be implemented to ensure compliance with relevant AML regulations and to safeguard the company from financial and reputational risks.

2. Scope: This policy applies to all employees, contractors, and third parties involved in the operations of Airvolt Inc. It covers all financial transactions, customer interactions, and business activities conducted by the company.

3. Responsibilities:

Senior Management: Ensure the implementation and enforcement of this AML Policy.

Compliance Officer: Oversee AML compliance, conduct regular audits, and report suspicious activities to relevant authorities.

Employees: Adhere to the AML Policy, report any suspicious activities, and participate in AML training programs.

4. Customer Due Diligence (CDD):

Conduct thorough CDD on all new customers before establishing business relationships.

Perform ongoing monitoring of existing customers to detect and report any unusual or suspicious transactions.

CDD involves a standard procedure for checking clients through sanctions lists and adverse media. Companies should be aware of changes in sanctions regimes as soon as they occur, using a special automated system that monitors sanctions regime updates. Before entering a business relationship or opening an account for a client, Airvolt Inc. must verify that we’re not onboarding someone listed as a target of financial sanction legislation—such as someone listed on the US Specially Designated Nationals List (SDN)—and confirm that there are no legal barriers to providing services.

CDD checks will be completed within 20 days of the initiation of the relationship. During this period, transactions involving unverified accounts will be restricted.

5. Measures for Unverified Clients:

If a client cannot be verified, the following measures will be taken: restrict account opening, limit transactions, block users, and other necessary actions to prevent potential risks.

Airvolt Inc. will not engage in business relationships with clients from high-risk or sanctioned countries and industries.

6. Transaction Monitoring:

Implement systems and procedures to monitor and analyze transactions for potential money laundering activities.

Report any suspicious transactions to the relevant authorities in accordance with legal requirements.

7. Training and Awareness:

Provide regular AML training to all employees to ensure they are aware of their responsibilities and the latest AML regulations.

Keep employees informed about any updates or changes to the AML Policy.

8. Reporting and Record-Keeping:

Maintain accurate records of all financial transactions and customer information for a minimum of five years.

Report any suspicious activities to the relevant authorities promptly and in accordance with legal requirements.

9. Investors and Shareholders Monitoring:

Conduct due diligence on all new investors and shareholders to ensure compliance with AML regulations.

Perform ongoing checks and monitoring of existing investors and shareholders to detect and report any unusual or suspicious activities.

Maintain transparent and up-to-date records of all investors and shareholders to ensure traceability and accountability.

10. Required Documents and Personal Data:

Gather and verify essential documents and personal data for all new customers and investors, including identification documents such as passports, passport numbers, national IDs, or incorporation certificates for corporate stakeholders.

Ensure the data collected is securely stored and regularly updated to maintain accuracy and compliance.

Conduct ongoing reviews to ensure the legitimacy and integrity of the information provided by customers and investors.

11. Information Verification:

Verify information through a combination of means, including collecting documents, biometrics, digital identity verification, and database searches.

Use verification software or manual methods to ensure the accuracy and legitimacy of the data provided by customers and investors.

12. AML Officer Appointment:

Appoint a designated AML Officer responsible for overseeing compliance with this policy.

The AML Officer’s contact information will be made available to all employees, contractors, and relevant third parties.

AML Officer Contact Information:

Name: Muhammad Rabee Altaf

Email: mrabee@airvolt.io

Phone: +92 321 3831455

13. Policy Review and Update:

Review and update this AML Policy regularly to ensure it remains effective and compliant with current regulations.

Document any changes and communicate them to all relevant parties.