This KYC & Anti-Money Laundering (AML) Policy is effective as of: 1st October, 2020

1. Introduction

It is the policy of Unos Finance LLC (“Unos”) to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as virtual currencies, money orders, or traveler’s checks, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase assets or to fund other criminal activities or legitimate businesses.

Our AML policies, procedures, and internal controls are designed to ensure compliance with all applicable regulations and rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures, and internal controls are in place to account for both changes in regulations and changes in our business.

The term “person” mentioned in this Policy means and includes “an individual, a corporation, a company, a partnership, a trust or estate, a joint-stock company, an association, a syndicate, joint venture, or other unincorporated organization or group and all entities cognizable as legal
personalities.” Further, the Policy includes and covers all the transactions undertaken through, including virtual currencies which is a medium of exchange, unit of account, or store of value that can operate like a currency that either has an equivalent value as currency, or acts as a substitute for currency, and is, therefore, a type of “value that substitutes for currency.”

2. Customer Identification

Unos will collect information, to the extent relevant, from its customers when a new account is opened on its website, mobile-optimized versions of the website, digital applications, and any other media formats to avail our services.

2.1. Required Customer Information

Prior to opening an account, Unos will collect the following information for all accounts, if relevant, for any person, entity, or organization that is opening a new account and whose name is on the account:

a) Name

b) Email address

c) an identification number, which will be a taxpayer identification number (for the U.S. persons), or one or more of the following: a taxpayer identification number, Social Security number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence.

d) Any one of PAN, aadhar, etc (for India)

e) When opening an account for a foreign business or enterprise that does not have an identification number, we will request alternative government-issued documentation certifying the existence of the business or enterprise.

2.2. Customers Who Refuse to Provide Information

If a potential or existing customer either refuses to provide the information described above when requested or appears to have intentionally provided misleading information, Unos will not open a new account and, after considering the risks involved, consider closing any existing account.

2.3. Verifying Information

Unos shall consider all the documents/details provided by the customer correct and reliable unless they’re a major reason for suspicion like the non-availability of appropriate documents. Appropriate documents for verifying the identity of customers include the following:

a) For an individual, an unexpired government-issued identification evidencing nationality or
residence similar safeguards, such as a driver’s license or passport; and

b) For a person other than an individual, documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement, or a trust instrument.
We understand that we are not required to take steps to determine whether the document that the customer has provided to us for verification has been validly issued and that we may rely on a government-issued identification as verification of a customer.

2.4. Lack of Verification

When we cannot form a reasonable belief that we know the true identity of a customer, we will do the following: (1) not open an account; (2) impose terms under which a customer may conduct transactions while we attempt to verify the customer’s identity, and (3) close an account after attempts to verify a customer’s identity fail;

2.5. Recordkeeping

a) We will save all the documents and details including all identifying information provided by the customer at the time of opening the account in electronic form which means creation and maintenance of records on our computers, servers, cloud storage, etc which are and can be convertible into written form.

b) We will retain records of all such information for five years after the account has been closed.

3. Customer Due Diligence Rule

3.1. All the information, details, and documents provided by the Customer to Unos during the account opening process and while undertaking a transaction shall be considered true and correct at the time made, remain true and correct at the time a transaction is executed, and such other time the customer uses the website and/or services offered by Unos.

3.2. The name in which the account is opened shall at all times be considered as the legal and beneficial owner of the account and all the transactions from such an account shall be considered as done by such customer.

4. Monitoring Accounts for Suspicious Activity

We will monitor account activity for unusual size, volume, pattern, or type of transactions, taking into account risk factors and red flags that are appropriate to our business. We will conduct the following reviews of activity:

a) Customers – Insufficient or Suspicious Information

● Provides unusual or suspicious identification documents that cannot be readily verified.

● Reluctant to provide information about nature and purpose of business, prior banking relationships, anticipated account activity, officers and directors, or business location, if asked for.

● Refuses to identify a legitimate source for funds or information is false, misleading, or substantially incorrect.

● The background is questionable or differs from expectations based on business activities.

● Customer with no discernible reason for using the Unos’s service.

b) Efforts to Avoid Reporting and Record keeping

● Reluctant to provide the information needed to file reports or fails to proceed with transactions.

● Tries to persuade an employee not to file required reports or not to maintain required records.

● “Structures” deposits, withdrawals, or purchases of monetary instruments below a certain amount to avoid reporting or recordkeeping requirements.

● The unusual concern with Unos’s compliance with government reporting requirements and Unos’s AML policies.

c) Certain Funds Transfer Activities

● Many small, incoming/outgoing transfers, almost immediately withdrawn or wired out in a manner inconsistent with the customer’s business or history.

● Wire activity that is unexplained, repetitive, unusually large, or shows unusual patterns or with no apparent business purpose.

5. Responding to Red Flags / Suspicious Transactions

When Unos detects any red flag or other activity that may be suspicious, Unos will determine whether or not and how to further investigate the matter. This may include gathering additional information internally or from third-party sources, contacting the government, freezing the account, etc.

6. AML Record keeping

We shall retain either the original or a microfilm or other copy or reproduction of each of the following:

● A record of each advice, request, or instruction received or given regarding ___;

● A record of each advice, request, or instruction given to another person, regarding ___;

7. Unos’s Vendors / Clearing Partners

We will work closely with our vendors/clearing partners who facilitate the completion of transactions triggered through our website, to detect money laundering. We will exchange

information, records, data, and exception reports, wherever necessary to comply with our contractual obligations to ensure that money laundering activities are not undertaken through the website. In case, our vendors/clearing partners raise a red flag on any transaction, it shall be looked into by Unos and respond as per clause 5 of this Policy.

8. Training Programs

We will develop ongoing employee training under the leadership of senior management. Our training will occur on an annual basis. It will be based on Unos’s size, its customer base, and its resources and be updated as necessary to reflect any new developments in the law.

Our training will include, at a minimum: (1) how to identify red flags and signs of money laundering that arises during the course of the employees’ duties; (2) what to do once the risk is identified (including how, when, and to whom to escalate unusual customer activity or other red flags for analysis); (3) what employees’ roles are in Unos’s compliance efforts and how to perform them, and (4) Unos’s record retention as per this policy.

Delivery of the training may include videos, intranet systems, in-person lectures, and explanatory memos. We will review our operations to see if certain employees, such as those in compliance, margin, and corporate security, require specialized additional training.

9. Monitoring Employee Conduct and Accounts

We will subject employee accounts to the same AML procedures as customer accounts, under the supervision of Unos.

10. Confidential Reporting of AML Non-Compliance

Employees will promptly report any potential violations of Unos’s AML Policy to the Officers of Unos. Such reports will be confidential, and the employee will suffer no retaliation for making them.

11. Additional Risk Areas

Unos has reviewed all areas of its business to identify potential money laundering risks that may not be covered in the procedures described above. Additional procedures to address other major risks shall be considered by the Officers of Unos and this Policy may be amended or
updated accordingly if required.

12. Officers Approval

The Officers of Unos have approved this AML Policy as reasonably designed to achieve and monitor Unos’s ongoing transactions and protection against AML transactions.