Qistiq Advance Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

1. Purpose

The purpose of this Policy is to:

• •Verify customer identity.
• •Prevent fraud and identity theft.
• •Detect and prevent money laundering.
• •Prevent terrorist financing.
• •Protect customers and the platform.
• •Comply with applicable legal and regulatory obligations.
• •Maintain a safe financial ecosystem.

2. Customer Identification Program (CIP)

Before providing services, Qistiq may verify the identity of each customer. Information that may be collected includes: Full Legal Name, Date of Birth, Nationality, Residential Address, Phone Number, Email Address, Government Identification Number.

3. Required Documentation

Qistiq may require identity verification (National ID Card, Passport, Driver License, Residence Permit), address verification (Utility Bill, Bank Statement, Government Correspondence), and income verification (Pay Stubs, Employment Letters, Bank Statements, Payroll Records).

4. Selfie and Biometric Verification

To protect against identity fraud, Qistiq may require:

• •Selfie verification
• •Liveness detection
• •Face comparison
• •Biometric verification tools

Verification results may be reviewed manually or through automated systems.

5. Risk-Based Approach

Qistiq applies a risk-based approach to customer verification. Risk factors may include customer location, account behavior, transaction patterns, device information, identity verification results, fraud indicators, and previous account history. Customers may be categorized as Low Risk, Medium Risk, or High Risk.

Additional verification may be required for higher-risk customers.

6. Ongoing Monitoring

Qistiq may continuously monitor:

• •Account activity
• •Login activity
• •Device activity
• •Repayment behavior
• •Transaction behavior
• •Fraud indicators

Monitoring may continue throughout the life of the customer relationship.

7. Sanctions Screening

Qistiq may screen customers against:

• •Government sanctions lists
• •Restricted persons lists
• •Terrorist financing lists
• •Regulatory watchlists
• •Other applicable screening databases

Accounts may be restricted or terminated if screening concerns arise.

8. Politically Exposed Persons (PEP)

Qistiq may identify and monitor Politically Exposed Persons ("PEPs"), their relatives, and close associates. Additional verification may be required where applicable.

9. Fraud Detection

Qistiq may use automated systems and artificial intelligence to detect:

• •Identity theft
• •Fake documents
• •Duplicate accounts
• •Account takeover attempts
• •Suspicious device activity
• •Suspicious payment activity
• •Synthetic identities

Fraud indicators may result in additional review or account restrictions.

10. Suspicious Activity Review

Qistiq reserves the right to review accounts for suspicious activity such as inconsistent identity information, multiple accounts for one individual, suspicious documents, unusual behavior, or circumvention attempts.

Accounts may be restricted while investigations are conducted.

11. Account Restrictions

Qistiq may suspend, restrict, or terminate accounts if:

• •Identity cannot be verified.
• •Fraud is suspected.
• •False information is provided.
• •AML concerns arise.
• •Regulatory obligations require action.

Qistiq is not obligated to disclose specific investigation details where prohibited by law.

12. Record Retention

Qistiq may retain identity verification records, KYC documentation, account activity records, risk assessments, investigation records, and payment records.

Records may be retained after account closure as required by applicable law.

13. Customer Responsibilities

Customers must:

• •Provide accurate information.
• •Submit authentic documents.
• •Cooperate with verification requests.
• •Update information when changes occur.
• •Respond to verification inquiries promptly.

Failure to comply may affect account eligibility.

14. AI and Automated Verification

Qistiq may use artificial intelligence and automated tools to assist with identity verification, document review, risk scoring, fraud detection, and transaction monitoring.

Automated systems may be supplemented by human review.

15. Compliance Reporting

Where required by law, Qistiq may cooperate with regulatory authorities, law enforcement agencies, courts, and government agencies.

Qistiq may disclose information when legally required.

16. Policy Changes

Qistiq may update this AML & KYC Policy at any time. Changes become effective upon publication or notification as permitted by law.