WeMasterTrade (referred to as "the Company", "we", "us") is 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 Company 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

• FINTRAC regulatory guidance

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

WeMasterTrade is a global proprietary trading evaluation platform at 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. The Company does not act as a bank, broker, investment adviser, money transmitter, or custodian.

This Policy applies to:

• All users accessing the WeMasterTrade platform globally

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

• All financial transactions processed in connection with the Company's services

The 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

The Company applies a risk-based approach to customer due diligence. All users are required to complete Know Your Customer (KYC) verification prior to accessing the platform. Verification is conducted through Sumsub, a regulated third-party identity verification provider. Sumsub supports automated identity verification, PEP screening, sanctions screening, and fraud prevention checks.

Standard CDD

• Government-issued photo identification

• Liveness / biometric verification

• Sanctions and PEP screening

Enhanced Due Diligence (EDD)

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 Company does not onboard anonymous users or users who refuse to provide required verification documentation.

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.

The Company does not provide services to users residing in or connected to sanctioned, embargoed, or high-risk jurisdictions. Access from restricted countries is blocked through IPbased geofencing and identity verification controls.

Sanctioned / Embargoed Countries:

• Cuba: CU

• Lebanon: LB

• Syria: SY

• Libya: LY

• Israel: IL

• Russia: RU

• Sudan: SD

• Somalia: SO

• South Sudan: SS

• Central African Republic: CF

• Democratic Republic of Congo: CD

• Nicaragua: NI

• Venezuela: VE

• Yemen: YE

• North Korea: KP• United States: US

• Iran: IR

• Vietnam: VN

The countries listed above are subject to international sanctions, regulatory restrictions, or have been identified as high-risk jurisdictions by the Financial Action Task Force (FATF), OFAC, UN Security Council, or our internal compliance review.

“Please note that this list is provided for informational purposes only and is subject to change based on updates to international regulations.”

The Company applies 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 Company reserves the right to delay, suspend, or reject transactions where concerns are identified. Where appropriate, external verification tools and Sumsub risk indicators may be used as part of enhanced review processes.

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

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

The Company retains 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.

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.

The Company conducts an enterprise-wide AML/CTF risk assessment annually, or upon any material change in products, jurisdictions, payment flows, customer profile, or regulatory requirements.

The assessment considers:

• customer risk

• geographic risk

• payment method risk

• transaction behavior risk

• third-party provider risk

Findings are reviewed by senior management and used to enhance internal controls where necessary.

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

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

For questions relating to this Policy: 📧 [email protected] | 🌐 WeMasterTrade