Abcm Digital TV (“we,” “us,” or “our”) is committed to complying with all applicable anti-money laundering (AML) laws and regulations to prevent the misuse of our services for illegal financial activities, including money laundering, terrorist financing, or other criminal activities. This Anti-Money Laundering Policy outlines our approach to identifying, mitigating, and managing AML risks.

1. Purpose

The purpose of this AML Policy is to:

• Prevent the misuse of Abcm Digital TV’s services for money laundering or other illicit activities.
• Establish procedures to detect, report, and mitigate suspicious activities.
• Comply with all relevant legal and regulatory requirements in jurisdictions where we operate.

2. Scope

This AML Policy applies to all employees, contractors, agents, and customers who engage with Abcm Digital TV. It governs all aspects of our business, including customer onboarding, transactions, and ongoing monitoring of customer activities.

3. Key Principles

3.1 Customer Due Diligence (CDD)

We implement a Customer Due Diligence process to verify the identity of our customers before providing services. This process includes:

• Collecting and verifying customer identification documents (e.g., government-issued ID, proof of address).
• Assessing the risk level of each customer based on factors such as location, transaction patterns, and business relationships.
• Enhanced due diligence (EDD) for high-risk customers or transactions.

3.2 Record Keeping

We maintain detailed records of:

• Customer identification information.
• Transaction history, including payment methods and amounts.
• Any reports of suspicious activities.

These records are retained for a minimum of 30 days or as required by applicable laws.

3.3 Monitoring and Reporting

We monitor customer transactions to identify unusual or suspicious activities, including but not limited to:

• Large or unusual transactions that are inconsistent with a customer’s profile.
• Transactions involving high-risk jurisdictions.
• Attempts to evade reporting thresholds.

Suspicious activities are reported to the relevant regulatory authorities in accordance with local AML regulations.

4. Prohibited Activities

We strictly prohibit:

• Engaging with customers or transactions that involve funds derived from illegal activities.
• Providing services to individuals, entities, or jurisdictions that are subject to sanctions or other regulatory restrictions.
• Structuring transactions to avoid reporting obligations.

5. Training and Awareness

We provide regular AML training to all employees and relevant contractors to ensure they understand:

• The importance of AML compliance.
• How to identify and report suspicious activities.
• Their responsibilities under this policy and applicable laws.

6. Responsibilities

6.1 Management

Our management team is responsible for:

• Overseeing the implementation and enforcement of this AML Policy.
• Ensuring adequate resources are allocated for AML compliance.
• Periodically reviewing and updating the policy to reflect changes in legal requirements or business practices.

6.2 Employees

All employees must:

• Follow the procedures outlined in this policy.
• Report any suspicious activities to the designated compliance officer.

6.3 Compliance Officer

We appoint a designated AML Compliance Officer who is responsible for:

• Implementing and maintaining AML procedures.
• Monitoring transactions and customer activities.
• Reporting suspicious activities to regulatory authorities.
• Acting as the primary point of contact for AML-related matters.

7. Risk Assessment

We regularly assess the risk of money laundering and other illicit activities associated with our services. This includes evaluating:

• Geographic risks.
• Customer risks.
• Transaction risks.
• Product and service risks.

Appropriate mitigation measures are implemented based on the results of the risk assessment.

8. Sanctions Compliance

We comply with all applicable sanctions programs and do not engage with individuals, entities, or jurisdictions on sanctions lists issued by:

• The United Nations.
• The European Union.
• The Office of Foreign Assets Control (OFAC).
• Other relevant authorities.

9. Reporting Obligations

In the event of suspicious activities or transactions, we promptly file reports with the relevant regulatory authorities, as required by law. We ensure that these reports are confidential and that no information about the report is shared with the customer involved.

10. Policy Review

This AML Policy is reviewed periodically to ensure its effectiveness and alignment with current legal and regulatory requirements. Any updates will be communicated to employees, customers, and stakeholders.

11. Contact Us

For questions or concerns regarding this AML Policy, please contact us at:

• Email: aml@abcmdigital.tv

By using Abcm Digital TV’s services, you agree to comply with this AML Policy. Non-compliance may result in the termination of services and, if necessary, reporting to the appropriate authorities.