Company: LVLM INVESTMENT GROUP - FZCO7

License Number: 61735

1. Purpose

This Anti-Money Laundering ("AML") and Know Your Customer ("KYC") Policy establishes the principles and procedures LVLM INVESTMENT GROUP - FZCO ("the Company") follows to prevent and detect any illegal activity including money laundering, terrorist financing, and fraudulent financial activities.

2. Scope

This Policy applies to all customers, users, employees, contractors, and stakeholders of LVLM INVESTMENT GROUP - FZCO globally.

3. Regulatory Compliance

The Company complies with AML regulations applicable in the United Arab Emirates, including the Dubai Financial Services Authority (DFSA) rules, and aligns its operations with global standards, including FATF recommendations and GDPR for EU-based clients.

4. Customer Due Diligence (CDD)

LVLM INVESTMENT GROUP - FZCO performs CDD at the onboarding stage and continuously thereafter. This includes:

• Identity verification (passport, government-issued ID).
• Proof of address (utility bills, bank statements not older than 3 months).
• Biometric verification (live selfie capture and face match).
• Wallet address verification for cryptocurrency transactions..
• Risk assessment profiling (geographical risk, transaction patterns).

5. Enhanced Due Diligence (EDD)

EDD is applied in higher-risk scenarios, including but not limited to:

• Clients from high-risk jurisdictions.
• Politically Exposed Persons (PEPs).
• Unusual transaction activities.

6. Ongoing Monitoring

The Company regularly monitors:

• Transactional activities.
• Changes in client risk profiles.
• Suspicious behavior patterns.

7. Reporting Obligations

Suspicious activities are reported to the appropriate regulatory authorities in compliance with local and international regulations.

8. Record Keeping

All KYC records, communications, and transaction data are securely maintained for a minimum of 5 years.

9. Sanctions Screening

All customers are screened against relevant sanctions lists, including but not limited to OFAC, UN, EU, and UAE sanctions lists.

10. Data Privacy

KYC and AML processes are conducted in compliance with GDPR and UAE Data Protection Laws. Clients' personal data is processed fairly, lawfully, and transparently.

11. Staff Training

All relevant personnel receive regular AML and KYC training to stay updated on obligations and procedures.

12. Policy Review

This policy will be reviewed and updated annually or as required by changes in regulatory requirements or Company operations.