1. Purpose and commitment

Akyol Fintech L.L.C-FZ (“Akyol Fintech”, “we”, “us” or “our”) supports responsible practices in financial technology and recognises the importance of preventing financial services, technology platforms and commercial relationships from being used for unlawful purposes.

Money laundering involves dealing with, transferring, concealing or otherwise handling proceeds of crime. Related financial crime risks include terrorist financing, proliferation financing, sanctions evasion, fraud, corruption and the concealment of criminal ownership or funds.

We aim to conduct business with integrity, understand relevant risks, apply proportionate controls and cooperate with competent authorities where legally required. We do not knowingly support activity intended to disguise criminal proceeds, evade sanctions or facilitate financial crime.

2. Scope and application

This policy sets out general principles for relevant business activities, personnel, contractors and relationships acting on behalf of Akyol Fintech, to the extent applicable to their roles and the company's legal obligations.

Depending on the nature of a service or engagement, relevant measures may apply to:

• Customer, supplier, partner and counterparty relationships.
• Technology, advisory and business support engagements connected with financial services.
• Customer or business information collected as part of onboarding or due diligence.
• Transactions or payment-related activities where Akyol Fintech is legally involved or responsible for a control.
• Outsourced services and third parties that support applicable financial crime controls.

Not every measure described in this policy necessarily applies to every service. Where a regulated bank, payment provider, exchange house or other authorised partner performs a regulated activity, that partner retains its own legal responsibilities. Contractual arrangements may also allocate specific checks and operational responsibilities between parties, without removing any obligation imposed directly by law.

3. Risk-based approach

We aim to assess financial crime risk in a manner proportionate to the activities undertaken and the information reasonably available. Where relevant, risk assessments may consider the customer, beneficial ownership, geography, products, delivery channels, counterparties, transaction purpose and complexity.

Risk assessments should be reviewed when material information changes, a new service or relationship is introduced, or a concern arises that may affect the original assessment.

4. Customer due diligence and verification

Where required by law, contract or the nature of a service, appropriate customer due diligence (“CDD”) may be undertaken before establishing a relationship, providing a service or processing an activity.

Depending on the risk and applicable requirements, checks may include:

• Identifying a customer or business and verifying identity using reliable information or documents.
• Understanding the nature and intended purpose of the relationship.
• Identifying relevant directors, authorised representatives and persons acting on behalf of a customer.
• Understanding ownership and control structures where applicable.
• Assessing the expected nature of activity and, where justified, the source of funds or source of wealth.
• Obtaining additional information or verification where the risk assessment indicates a need.

We aim to collect information that is relevant and proportionate to the purpose of the check. Information requests may vary by customer type, jurisdiction, risk profile and the requirements of an authorised service provider.

Enhanced due diligence

Where higher risk is identified and enhanced due diligence is required, additional steps may include further verification, clarification of ownership or source of funds, senior-level approval where applicable, closer monitoring, or restrictions on establishing or continuing a relationship.

If required information cannot be obtained or verified, the relevant activity may be delayed, restricted, declined or discontinued, subject to applicable law and contractual obligations.

5. Beneficial ownership and control

Where relevant, we seek to understand who ultimately owns or controls a business or legal arrangement. This may involve reviewing ownership records, control rights, corporate structures, authorised representatives and other relevant information.

Complex, opaque or inconsistent structures may require additional clarification. Where the information available does not provide a reasonable understanding of the ownership or control of a relevant customer or counterparty, the relationship may be escalated for review and may not proceed until the concern is appropriately addressed.

6. Politically exposed persons and sanctions

Politically exposed persons

Where relevant and required, screening may be used to identify politically exposed persons (“PEPs”), their relevant family members or close associates, in accordance with applicable definitions and legal requirements. A PEP designation does not by itself establish wrongdoing.

Where enhanced measures are required, these may include additional due diligence, assessment of source of funds or source of wealth, approval by an appropriate decision-maker and ongoing monitoring.

Sanctions and restrictive measures

Where applicable, relevant parties and activity may be screened against sanctions lists and other legally applicable restrictive measures. Potential matches should be assessed carefully to distinguish genuine matches from false positives.

Where a confirmed match or other legal restriction requires action, the relevant activity may be prohibited, paused, restricted or escalated, and any legally required reporting or freezing action should be handled by the responsible party in accordance with applicable law.

Screening arrangements, lists, frequency and escalation procedures should reflect the company's actual activities and the obligations applicable to the relevant entity or service.

7. Monitoring and indicators of concern

Where Akyol Fintech has a monitoring responsibility, or where information comes to its attention in the course of an engagement, activity may be reviewed for inconsistencies or indicators of potential financial crime.

Examples of concerns may include:

• Unclear or inconsistent explanations for the purpose of a relationship or transaction.
• Unexplained third-party payments or funds that do not appear consistent with the stated activity.
• Unusual transaction patterns, rapid movement of funds or activity without a credible commercial rationale.
• Attempts to conceal ownership, control, the source of funds or the identity of a party.
• Documents or information that appear false, altered, contradictory or misleading.
• Potential sanctions matches, suspected sanctions evasion or links to prohibited activity.
• Reluctance to provide reasonable information required for applicable due diligence.

These indicators do not automatically prove criminal activity. Concerns should be assessed in context, documented where appropriate and escalated through the relevant process.

8. Internal escalation and external reporting

Personnel who identify a reasonable concern about possible money laundering, terrorist financing, proliferation financing, sanctions evasion or related financial crime should raise it promptly through the appropriate internal channel.

Concerns should be handled confidentially and reviewed by the person or function responsible for the relevant matter. Where legally required, the responsible entity must make reports to the appropriate competent authority or financial intelligence unit within the applicable timeframes.

This public policy does not designate a statutory reporting officer or assert that Akyol Fintech has access to any particular reporting system. Those arrangements must be defined internally according to the company's legal status, activities and applicable obligations.

No person should alert a customer or another party to a confidential report or investigation where doing so would breach applicable law or compromise a lawful investigation. This includes avoiding prohibited “tipping off”.

9. Record keeping, data protection and confidentiality

Where due diligence, screening, monitoring or other financial crime controls are required, relevant records should be maintained securely for the period required by applicable law and contractual obligations.

Depending on the activity, records may include verification evidence, risk assessments, screening outcomes, relevant correspondence, decisions, approvals and supporting information.

Access to such information should be limited to authorised persons with a legitimate business or legal need. Personal information should be handled in accordance with applicable data-protection requirements and Akyol Fintech's Privacy Policy.

Records should not be destroyed or altered in a way that obstructs a legal obligation, audit, investigation or lawful request from a competent authority.

10. Partners, suppliers and third parties

Where third parties provide relevant services or support financial crime controls, we aim to understand their role, responsibilities and the risks associated with the arrangement.

Depending on the relationship, this may include reviewing business credentials, relevant contractual commitments, security and data-handling arrangements, service responsibilities and escalation procedures.

Using an external service provider does not automatically transfer or remove any legal responsibility that applies directly to Akyol Fintech. Responsibilities should be clearly allocated and monitored as appropriate to the arrangement.

11. Governance, accountability and awareness

Akyol Fintech aims to promote awareness of financial crime risks proportionate to its activities. Relevant personnel should understand the controls applicable to their responsibilities and know how to escalate concerns.

Where required, the company should establish appropriate responsibility for policy oversight, risk assessment, control implementation, record keeping, training and the handling of concerns. Training and guidance should be suitable for the person's role and updated when material requirements or risks change.

The actual allocation of responsibility, approval authority and reporting lines should be documented internally and aligned with any applicable regulatory requirements.

12. Non-compliance and prohibited conduct

Akyol Fintech does not knowingly support activity intended to conceal criminal proceeds, facilitate terrorist financing, evade sanctions or circumvent applicable financial crime controls.

Depending on the circumstances and applicable law, a concern may result in additional checks, a request for information, escalation, refusal or suspension of a service, termination of a business relationship or notification to a competent authority where required.

Any internal response should be proportionate, documented where appropriate and consistent with legal and contractual obligations. Nothing in this policy authorises a person to disregard a legal reporting, sanctions or other mandatory requirement.

13. Review and updates

This policy may be reviewed and updated to reflect changes in applicable law, regulatory guidance, business activities, services, risks or internal controls.

Akyol Fintech will publish the current public version on this page. Internal procedures, where required, may contain further operational details that are not appropriate for publication on a public website.

14. Contact Akyol Fintech

For general questions about this policy or Akyol Fintech's approach to financial crime prevention, please contact us using the details below. This contact channel is not a substitute for a legally required report to a competent authority.