ANTI-MONEY LAUNDERING (AML), KNOW YOUR CUSTOMER (KYC) AND COUNTER-TERRORIST FINANCING (CTF) POLICY

To prevent the infiltration of illicit funds into the economy and to combat criminal activity, many countries implement measures aimed at preventing money laundering and terrorist financing. NORTA HOLDING CORP has established and applies all necessary due diligence procedures to identify, assess, and mitigate the risk of being involved in unlawful activities. The company maintains a strict and principled approach to preventing illegal operations and complies with all applicable regulatory requirements.

In fulfilling its legal obligations, NORTA HOLDING CORP is required to report any suspicious customer activity to the relevant authorities where there are reasonable grounds to believe that funds may be linked to money laundering and/or terrorist financing. In such cases, the company may freeze the relevant funds and take additional actions in accordance with its internal AML policies and applicable legislation.

Money Laundering (ML) refers to:

• concealing or failing to disclose the true origin, source, location, movement, ownership, or rights related to assets or funds derived from illegal activities (including assets obtained in exchange for such proceeds);
• converting, transferring, acquiring, possessing, or using assets obtained through criminal activity in order to disguise their unlawful origin or to assist individuals involved in such activities in avoiding legal consequences;
• situations where assets or funds are derived from criminal activities committed in another jurisdiction.

Terrorist Financing (TF) refers to:
• the collection or provision of funds with the intention or knowledge that they may be used to support terrorist acts or organizations.

Risk Assessment

NORTA HOLDING CORP applies a risk-based approach to Customer Due Diligence (CDD) and continuous monitoring. Where higher risks of money laundering or terrorist financing are identified, enhanced due diligence measures are implemented to effectively manage and reduce those risks.

Risk assessments form the foundation of the company’s AML framework. These assessments are conducted both at the organizational and customer levels to determine the extent of exposure to ML/TF risks.

At the customer level, NORTA HOLDING CORP evaluates risks based on:

a) the customer profile;
b) the jurisdictions in which customers are located;
c) the jurisdictions where the company operates;
d) the products, services, transaction types, and delivery channels used.

The company utilizes a weighted AML risk scoring model to assess both prospective and existing customers, taking into account all data collected during the due diligence process. Based on the assigned risk level, appropriate monitoring frequency and enhanced controls are applied.

A designated Compliance Officer is responsible for overseeing the implementation and enforcement of the AML policy within NORTA HOLDING CORP.

Customer Obligations

By engaging with NORTA HOLDING CORP., the Customer agrees to:

• comply with all applicable laws and regulations related to anti-money laundering and counter-terrorist financing;
• confirm that they have no knowledge or suspicion that the funds or crypto assets used in transactions (past, present, or future) originate from illegal sources or are connected to unlawful activities;
• promptly provide any information requested by the company to ensure compliance with legal and AML requirements.

Data Handling and Monitoring

NORTA HOLDING CORP reserves the right to share collected information, including personal data and transaction records, with relevant authorities for the purposes of investigating fraud, money laundering, or other illegal activities.

The company uses certified third-party providers to collect and securely store identification data, monitor transactions for suspicious activity, and maintain comprehensive transaction records.

At any stage, NORTA HOLDING CORP may suspend or cancel transactions if there is reason to believe they are linked to money laundering, terrorist financing, or other criminal conduct.

In accordance with AML laws and international regulations, the company is not obligated to inform customers if their activities are reported as suspicious to competent authorities.

Customer Due Diligence (CDD)

Under its internal AML policy, NORTA HOLDING CORP conducts both initial and ongoing customer due diligence based on the assessed risk level. As part of this process, the company may:

• request minimum identification data required to verify the customer’s identity;
• collect and store identification documents (via third-party providers), including verification methods and results;
• screen customer data against PEP (Politically Exposed Persons), sanctions lists, and terrorism watchlists maintained by governmental and independent authorities. The minimum identification data includes full name, date of birth, and residential address;
• request information regarding the source of funds intended for use.

KYC Verification

To confirm the authenticity of provided information, NORTA HOLDING CORP may require customers to complete a KYC (Know Your Customer) procedure, including submission of:

• a valid passport, national ID card, or equivalent government-issued document containing full name, date of birth, and photograph;
• a recent utility bill (issued within the last 3 months) or other valid proof of residential address.

The company may also request additional supporting documents where necessary. In certain cases, notarized copies of documents may be required.