ANTI-MONEY LAUNDERING POLICY

Effective from: 28 February 2022

Introduction
This document describes Upstars Limited, a company incorporated under the laws of Marshall Islands, with the registered office at: Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands MH96960, registration number 113145 (further Upstars) policy and commitment to the detection and prevention of any money-laundering or terrorism financing activity within the products and services offered by Upstars to its customers.
This Policy covers the following areas:

• Adoption of a risk-based approach
• Know Your Client (KYC) Policy and Customer Due Diligence
• Customer activity monitoring
• Record Keeping
• Adoption of a Risk Based Approach

Identification of the money laundering risks of customers and transactions allow Upstars to determine and implement proportionate measures to control and mitigate these risks. Used risk criteria are the following:
1. Country Risk
In conjunction with other risk factors, Upstars provides useful information as to potential money laundering risks. Factors that may result in a determination that a country poses a heightened risk include:

• Countries subject to sanctions, embargoes or similar measures;
• Countries identified by the Financial Action Task Force (“FATF”) as non-cooperative in the fight against money laundering or identified by credible sources as lacking appropriate money laundering laws and regulations;
• Countries identified by credible sources as providing funding or support for terrorist activities.

2. Customer Risk
There is no universal consensus as to which customers pose a high risk, but the below listed characteristics of customers have been identified with potentially heightened money laundering risks:

• Armament manufacturers;
• Cash intensive business;
• Unregulated charities and other unregulated “non-profit” organizations.
• Customer Acceptance

Upstars obtains sufficient information in order to undertake its risk assessment and determine the potential exposure to ML/FT risks and to justify the applicable level of due diligence to mitigate those risks.
Upstars obtains sufficient detail from merchant applications to enable it to assess the risks. Relevant information contained therein might be corroborated by either appropriate electronic means or by suitable documentation. Initial due diligence should be supported by the use of transaction monitoring to assist in the identification of activity (such as volume of transactions, etc.) that may be indicative of money laundering and other illegal activity.
Therefore, on a Risk Based Approach, relevant evidential documentation must be requested where a change in circumstances in respect of their trading patterns, amounts and currencies, frequency or recipients occur. Prior to the onboarding of a legal entity, the below minimum information must be obtained by the Upstars and then verified with documentation or online checks if applicable:

• Company Name and Trading name (if different);
• Company registration number and date of incorporation;
• Business telephone number and email address;
• Business website(s);
• Description of main business including products and services;
• Directors: names, date of birth, nationality;
• UBOs (Ultimate Beneficial Owners) down to 25%: names, date of birth, nationality, the percentage owned.

Upstars collects the below listed verification documents for legal entities prior to the onboarding in order to fully meet its Compliance standards:
Applying Company:

• Filled in Application Form, signed by Director or authorized person;
• Certificate of Incorporation/ Registration;
• Memorandum / Articles of Association;
• Directors Register;
• Recent Certificate of Good Standing (dated not older than 3 months); if the company is incorporated in an offshore jurisdiction, Certificate of incumbency additionally to be collected;
• UBOs Passport Copies (colour copies) and Recent Utility Bill;
• Directors Passport Copies (colour copies) and Recent Utility Bill;
• Company proof of address (utility bill or bank statement in the company’s name, issued within the last 3 months);
• Other documents we deem necessary and appropriate to identity the company.

When the owner of the Applying Company is another Company(s) additionally to collect the bellow documentation for the company UBO:

• Certificate of Incorporation / Registration;
• Memorandum & Articles of Association;
• Shareholders Register.

3. Service Risk
Determining the money laundering risks of services should include a consideration of such factors as services identified by regulators, governmental authorities or other credible sources as being potentially high risk for money laundering.
Upstars has established non-acceptable use policy which to clearly indicate the business models which are not among the acceptable ones. Those include, but are not limited to:

• Material which incites or promote violence and/or racism;
• Any goods or services that infringe on the intellectual property rights of third parties;
• undefined
• Prepaid or other stored value cards that are not associated with a particular merchant and/or are not limited to purchases of particular products or services;
• Unlicensed gambling services of any type.

Know Your Customer and Customer Due Diligence
Upstars is an online operating company and therefore business relationships between the company and its customers are not established on a face-to-face basis. For customer identification purpose Upstars uses electronic data brokers (linked with other in-house checks e.g., identifying duplicate accounts, confirming ownership of bank accounts etc.) to provide identity verification. This will be used to determine and document the true identity of customers to obtain background information on customers as well as purpose and intended nature of their business to us.

Upstars shall obtain and document any additional customer information, commensurate with the assessment of the money laundering risk using Risk Based Approach.
Upstars shall identify whether the customer is acting on behalf of another natural person or legal entity as trustee, nominee or professional intermediary. In such case obligatory precondition of customer serve is receipt of satisfactory evidence of the identity of any intermediaries and of the persons on whose behalf they are acting, as well as the nature of the trust arrangements in place.
Record Keeping
Records must be kept of all documents obtained for the purpose of customer identification (KYC policy requirements) and all data of each transaction as well as other information related to money laundering matters in accordance with the applicable anti-money laundering laws/regulations. That includes files on suspicious activity reports, documentation of AML account monitoring, etc. Those records must be kept for a minimum of 5 years.