ANTI-MONEY LAUNDERING (AML) & KNOW YOUR CUSTOMER (KYC) POLICY

1. Purpose

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines the procedures adopted by Winwestor Inc. (“the Company”, “we”, “our”) to prevent, detect, and report potential money laundering, terrorist financing, fraud, and other financial crimes. The Company is committed to operating with integrity and ensuring that its platform is not used for unlawful purposes.

2. Scope of Application

This policy applies to:

• All users of the Winwestor platform
• Clients, partners, and counterparties
• Any individual or entity engaging with projects, services, or opportunities presented via the platform

3. Regulatory Position

Winwestor Inc. operates as a technology and project introduction platform and does not act as:

• A financial institution
• A regulated investment firm
• A custodian of client funds

However, the Company adopts AML/KYC procedures aligned with US and international best practices to mitigate financial crime risk.

4. Risk-Based Approach

The Company applies a risk-based approach to AML/KYC, meaning that the level of due diligence conducted depends on the assessed risk profile of the user or transaction. Risk factors may include:

• Jurisdiction of residence or incorporation
• Nature of activity
• Transaction size or behaviour patterns
• Association with high-risk industries or regions

5. Customer Due Diligence (CDD)

The Company may require users to complete identity verification before accessing certain services or opportunities.

5.1 Individual Verification

Users will be required to provide:

• Full legal name
• Date of birth
• Residential address
• Government-issued identification (passport or ID card)
• Proof of address (where applicable)

5.2 Business Verification

For corporate entities:

• Registered company name and number
• Registered address
• Details of directors and beneficial owners
• Corporate documentation (e.g. certificate of incorporation)

6. Enhanced Due Diligence (EDD)

Enhanced checks may be conducted in higher-risk scenarios, including:

• Politically Exposed Persons (PEPs)
• High-value transactions
• Users from high-risk jurisdictions

EDD may include:

• Source of funds verification
• Source of wealth assessment
• Additional identity documentation

7. Ongoing Monitoring

The Company may monitor:

• User activity and behaviour
• Transaction patterns
• Platform usage

Unusual or suspicious activity may trigger further review or account restriction.

8. Sanctions Compliance

Winwestor Inc. is committed to ensuring that its platform is not used in connection with individuals, entities, or jurisdictions subject to financial sanctions or restrictions.

The Company may screen users and counterparties against applicable sanctions lists, including but not limited to:

• United Kingdom: HM Treasury (OFSI) Consolidated List
• European Union: EU Consolidated Sanctions List
• United States: Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List
• International Bodies: United Nations Security Council Sanctions List
• Other Jurisdictions: Relevant sanctions frameworks applicable to regions in which users operate, including parts of Africa and Asia where local or regional restrictions may apply

Screening may be conducted at onboarding and on an ongoing basis.

Where a user, beneficial owner, or associated party is identified as:

• Listed on a sanctions register
• Located in, or operating from, a sanctioned or high-risk jurisdiction
• Connected to restricted individuals or entities

the Company reserves the right to:

• Deny or restrict access to the platform
• Suspend or terminate user accounts
• Refuse to engage in any activity or transaction
• Take any further action deemed necessary to ensure compliance with applicable laws and internal risk controls

Winwestor Inc. does not permit the use of its platform for activities that would breach applicable sanctions laws or facilitate prohibited transactions.

9. Reporting Suspicious Activity

Where suspicious activity is identified, the Company reserves the right to:

• Suspend or terminate user access
• Refuse or restrict services
• Report activity to relevant authorities where required

10. Data Protection

All personal data collected for AML/KYC purposes is processed in accordance with the Company’s Privacy Policy and applicable data protection laws.

11. Record Keeping

The Company retains AML/KYC records for a reasonable period in line with legal and operational requirements.

12. Policy Updates

This policy may be updated periodically to reflect regulatory developments and operational changes.

13. Contact Information

For general enquiries regarding this policy, please contact us at: