Anti-Money Laundering (AML) PolicyAnti-Money Laundering (AML) Policy

Anti-money Laundering & Counter-terrorism Financing Policy

WeMasterTrade LTD | WeCopy Fintech Inc.
Last Updated: April 2026

1. INTRODUCTION

WeMasterTrade LTD and WeCopy Fintech Inc. (collectively referred to as "the Companies", "we", "us") are committed to the prevention of money laundering, terrorism financing, and other financial crimes. This Anti-Money Laundering and Counter-Terrorism Financing Policy ("AML/CTF Policy") sets out the principles and procedures adopted by the Companies to comply with applicable laws and international standards.

Our AML/CTF framework is aligned with:

• The Financial Action Task Force (FATF) 40 Recommendations

• The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), Canada — applicable to WeCopy Fintech Inc.

• FINTRAC regulatory guidance — applicable to WeCopy Fintech Inc.

• Applicable EU, UK, and international AML/CTF standards

2. ABOUT THE COMPANIES

WeMasterTrade LTD is incorporated in Saint Lucia (Registration No. 2025-00321) and operates a global proprietary trading evaluation platform at wemastertrade.com (https://wemastertrade.com/). All trading activity on the platform is conducted in a fully simulated environment using demo accounts. No real funds are traded on behalf of users. Users pay a one-time access fee to participate in evaluation programs. Performance-based rewards may be granted at the sole discretion of the Company from its own revenue pursuant to contractual agreements, and do not constitute investment returns, guaranteed income, or financial services. The Company does not hold, manage, transmit, or custody any client funds.

The Company does not establish any fiduciary, client, or investment relationship with users.

WeCopy Fintech Inc. is incorporated in British Columbia, Canada (Incorporation No. BC1333534) and operates WeCopyTrade, an automated copy trading platform at wecopytrade.com (http://wecopytrade.com/). WeCopy Fintech Inc. is registered as a Money Services Business (MSB) and is subject to AML/CTF obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and FINTRAC regulatory guidance.

3. SCOPE

This Policy applies to:

• All users accessing the WeMasterTrade and WeCopyTrade platforms globally

• All employees, contractors, officers, and agents of the Companies

• All financial transactions processed in connection with the Companies' services

4. COMPLIANCE FUNCTION

Each Company has designated a responsible compliance function to oversee the implementation and enforcement of this Policy. The compliance function is responsible for:

• Implementing and maintaining AML/CTF procedures

• Conducting and overseeing customer due diligence

• Monitoring transactions for suspicious activity

• Filing reports with relevant competent authorities where required

• Ensuring staff training and awareness

5. CUSTOMER DUE DILIGENCE (CDD) AND KYC

The Companies apply a risk-based approach to customer due diligence. All users are required to complete Know Your Customer (KYC) verification prior to accessing either platform. Verification is conducted through Sumsub, a regulated third-party identity verification provider.

Standard CDD includes:

• Government-issued photo identification

• Liveness / biometric verification

• Sanctions and PEP screening

Enhanced Due Diligence (EDD) is applied to users presenting elevated risk indicators, including Politically Exposed Persons (PEPs), users from higher-risk jurisdictions, and accounts exhibiting unusual activity patterns. EDD may require proof of address, source of funds documentation, and senior management approval.

The Companies do not onboard anonymous users or users who refuse to provide required verification documentation.

6. SANCTIONS SCREENING

All users are screened against applicable international sanctions lists, including:

• OFAC Specially Designated Nationals (SDN) List

• UN Security Council Consolidated Sanctions List

• EU Consolidated Financial Sanctions List

• UK HM Treasury Financial Sanctions Targets

Any confirmed sanctions match results in immediate account suspension and reporting to relevant authorities.

7. RESTRICTED JURISDICTIONS

The Companies do not provide services to users residing in or connected to sanctioned, embargoed, or high-risk jurisdictions. Access from restricted countries is blocked through IP-based geofencing and identity verification controls. The full list of restricted jurisdictions is published at: Who Can Sign Up ?

8. TRANSACTION MONITORING

The Companies apply a risk-based approach to monitoring payment activity associated with user accounts on an ongoing basis. Unusual or suspicious patterns — including structuring, inconsistent payment origins, or abnormal payout requests — are subject to enhanced review. The Companies reserve the right to delay, suspend, or reject transactions where concerns are identified.

9. SUSPICIOUS ACTIVITY REPORTING

Where either Company identifies or reasonably suspects activity related to money laundering or terrorism financing, it will file a Suspicious Transaction Report (STR) with the relevant competent authority in accordance with applicable law:

• WeCopy Fintech Inc. reports to FINTRAC (Canada)

• WeMasterTrade LTD reports to the relevant authority in Saint Lucia and/or the jurisdiction of the suspected activity

All related records are retained for a minimum of five (5) years.

The Companies strictly observe the tipping-off prohibition: users will not be notified that a report has been or may be filed.

10. TRANSACTION MONITORING

The Companies retain all KYC documentation, transaction records, and compliance-related materials for a minimum of five (5) years from the date of collection, or longer where required by applicable law. All records are stored securely with access limited to authorised personnel.

11. STAFF TRAINING

All relevant staff receive AML/CTF training upon onboarding and on an annual basis to ensure awareness of obligations, red flag indicators, and reporting procedures.

12. THIRD-PARTY PAYMENT PROVIDERS

The Companies process user payments exclusively through regulated third-party payment service providers (PSPs). All PSPs engaged by the Companies are subject to due diligence to confirm their regulatory status and compliance standards.

13. POLICY REVIEW

This Policy is reviewed annually and updated as required to reflect changes in applicable law, regulatory guidance, or the Companies' business operations.

14. CONTACT

For questions relating to this Policy:

WeMasterTrade LTD: 📧 [email protected] | 🌐 wemastertrade.com

WeCopy Fintech Inc.: 📧 [email protected] | 🌐 wecopytrade.com

* Disclaimer: WeMasterTrade LTD operates a simulated trading environment. No real financial instruments are traded on behalf of users. This Policy relates solely to the prevention of financial crime in connection with the Companies' access fees and payout activities.

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