This Anti-Money Laundering and Know Your Client Policy (hereafter referred to as the "Policy") is intended to prevent and mitigate Metzora's involvement in any type of illicit conduct.

Metzora employs effective internal procedures and tools to prevent the illegal transfer of assets, drugs, humans, organs, and other illegal trafficking, poaching, pornography, arms trade, terrorism and crime financing, corruption, bribery, and money laundering, and takes action in cases of suspicious activity by its Clients.

This policy contains verification methods, a compliance officer, transaction monitoring, and risk assessment.

1. VERIFICATION OF CUSTOMERS

1.1. One of the international standards for preventing illegal activity is client due diligence. Metzora Capital has established its own verification procedures within the standards of “Know Your Client” frameworks.

1.2. The Metzora Capital identity verification procedure requires the Client to provide Metzora Capital with reliable, independent-source documents, data or information. Metzora Capital reserves the right to collect Clients’ identification information to meet the requirements of the Policy.

1.3. Metzora Capital will take steps to confirm the authenticity of documents and information provided by Clients. All legal methods for double-checking identification information will be used and Metzora Capital reserves the right to investigate certain Clients who match a higher risk profile or appear suspicious.

1.4. Metzora Capital reserves the right to review Clients’ proofs of identity on an on-going basis, especially where identification information has changed or activity appears suspicious / unusual for a particular Client. Metzora can decide which traits / activities are deemed suspicious at its sole discretion.

1.5. Metzora reserves the right to request up-to-date documents from the Clients, even if they have previously passed identity verification.

1.6. Clients’ identification information will be collected, stored, shared and protected strictly in accordance with the Metzora Privacy Policy.

2. PAYMENT AND TRANSACTIONS PROCESSING

2.1. Metzora strictly prohibits using the Services through anonymous proxy servers or other anonymising Internet connection.

s using the Services through anonymous proxy servers or other anonymising Internet connection.

2.2. In order to prevent potentially unlawful transactions, Metzora requires the recipient of a payment to be the same person as the sender. Payments in favor of a third party are strictly prohibited.

2.3. Card funding options require 3D Secure processing. 3. COMPLIANCE OFFICER

The Compliance Officer is the person, duly authorized by Metzora Capital, whose duty it is to ensure the effective implementation and enforcement of the Policy. The Compliance Officer is obliged to have relevant education and specific knowledge and expertise in AML fundamental and practical issues.

3.2. It is the Compliance Officer’s responsibility to supervise all aspects of implementing the Policy including, but not limited to: collecting Clients’ identification information; establishing and updating internal policies and procedures for the completion, review, submission, and retention of all reports and records required under applicable laws and regulations; monitoring the transfer of assets and investigating any significant deviations from normal transfer activity; implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs; and regularly updating risk assessment.

P>3.3. The Compliance Officer is entitled to interact with competent authorities involved in the prevention of all types of illegal activity.

4. MONITORING OF TRANSACTIONS

4.1. In order to prevent unlawful activity, Metzora Capital also uses internal automated systems for analyzing transactions and Clients’ behavior; blocking suspicious activity; setting limits on Clients’ transactions; observing the Know-Your-Client policy; and performing verification of the data provided by Clients by employing any available means. Metzora Capital analyses what Clients do on the platform and relies on analysis of that data as a risk-assessment and suspicion detection tool. Metzora Capital may perform a variety of compliance-related tasks, including capturing of data, filtering, record-keeping, investigation management, and reporting.

4.2. Metzora Capital uses block chain monitoring tools for Client deposit or withdrawal crypto-currency transactions exceeding the equivalent of 1,000 units of fiat currency.

4.3. Metzora Capital implements additional verifications and manual processing of withdrawal transactions exceeding the equivalent of 5,000 units of fiat currency.

4.4. Monitoring system functionalities include: aggregating transfers of assets by multiple data points, placing Clients on watch and service denial lists, opening cases for investigation where needed and sending internal сase and document management notices.

4.5. With regard to the Policy, Metzora Capital will monitor all transfers of assets and it reserves the right to: ensure that transfers of assets of suspicious nature are reported to the proper competent authority through the Compliance Officer; request the User to provide additional information and documentation for suspicious transfers of assets; suspend or terminate Clients’ Accounts where Metzora Capital has reasonable suspicion that such Clients are engaged in illegal activity.

4.6. Metzora Capital sets limits on withdrawals of funds initiated earlier than 3 (three) days after initial Account funding, or after changes in Clients’ account data, password recovery, password reset, or change of authorization method.

>4.7. Use of the Services for purposes other than those provided for in the Terms and Conditions (in particular, for the deposit and withdrawal of funds in the absence of trading activity), may be deemed suspicious and are prohibited.

.8. The above list is not exhaustive - Internal Control Specialists constantly monitor the Transactions of Clients to determine whether transactions should be treated as suspicious.

5. RISK ASSESSMENT

Metzora Capital, in line with international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. This enables Metzora Capital to ensure that measures aimed at preventing illegal activities are commensurate with identified risks. The principle involves directing resources in accordance with priorities so that the greatest risks receive the highest attention.

2.2. In order to prevent potentially unlawful transactions, Metzora Capital requires the recipient of a payment to be the same person as the sender. Payments in favor of a third party are strictly prohibited.

>2.3. Card funding options require 3D Secure processing.

3. COMPLIANCE OFFICER

3.1. The Compliance Officer is the person, duly authorized by Metzora Capital, whose duty it is to ensure the effective implementation and enforcement of the Policy. The Compliance Officer is obliged to have relevant education and specific knowledge and expertise in AML fundamental and practical issues.

3.2. It is the Compliance Officer’s responsibility to supervise all aspects of implementing the Policy including, but not limited to: collecting Clients’ identification information; establishing and updating internal policies and procedures for the completion, review, submission, and retention of all reports and records required under applicable laws and regulations; monitoring the transfer of assets and investigating any significant deviations from normal transfer activity; implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs; and regularly updating risk assessment.

3.3. The Compliance Officer is entitled to interact with competent authorities involved in the prevention of all types of illegal activity.

4. MONITORING OF TRANSACTIONS

4.1. In order to prevent unlawful activity, Metzora Capital also uses internal automated systems for analyzing transactions and Clients’ behavior; blocking suspicious activity; setting limits on Clients’ transactions; observing the Know-Your-Client policy; and performing verification of the data provided by Clients by employing any available means. Metzora Capital analyses what Clients do on the platform and relies on analysis of that data as a risk-assessment and suspicion detection tool. Metzora Capital may perform a variety of compliance-related tasks, including capturing of data, filtering, record-keeping, investigation management, and reporting.

4.2. Metzora Capital uses block chain monitoring tools for Client deposit or withdrawal crypto-currency transactions exceeding the equivalent of 1,000 units of fiat currency.

4.3. Metzora Capital implements additional verifications and manual processing of withdrawal transactions exceeding the equivalent of 5,000 units of fiat currency.

>4.4. Monitoring system functionalities include: aggregating transfers of assets by multiple data points, placing Clients on watch and service denial lists, opening cases for investigation where needed and sending internal сase and document management notices.

4.5. With regard to the Policy, Metzora Capital will monitor all transfers of assets and it reserves the right to: ensure that transfers of assets of suspicious nature are reported to the proper competent authority through the Compliance Officer; request the User to provide additional information and documentation for suspicious transfers of assets; suspend or terminate Clients’ Accounts where Metzora Capital has reasonable suspicion that such Clients are engaged in illegal activity.

4.6. Metzora Capital sets limits on withdrawals of funds initiated earlier than 3 (three) days after initial Account funding, or after changes in Clients’ account data, password recovery, password reset, or change of authorization method.

4.7. Use of the Services for purposes other than those provided for in the Terms and Conditions (in particular, for the deposit and withdrawal of funds in the absence of trading activity), may be deemed suspicious and are prohibited.

4.8. The above list is not exhaustive - Internal Control Specialists constantly monitor the Transactions of Clients to determine whether transactions should be treated as suspicious.

5. RISK ASSESSMENT

Metzora Capital, in line with international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. This enables Metzora Capital to ensure that measures aimed at preventing illegal activities are commensurate with identified risks. The principle involves directing resources in accordance with priorities so that the greatest risks receive the highest attention.

6. AML OWNERSHIP CERTIFICATE

for any investor account with a account balance of more than $100,000 It is a requirement for investors to provide AML proof of funds ownership certificate. Investors must follow Metzora rules and implementing regulations in order to recognize and report suspicious conduct, including predicate offenses to money laundering and terrorism financing, such as securities fraud and market manipulation.

RENMAINING FUNDS AFTER ACCOUNT TERMINATION (FRAUD/AML/VIOLATION OF TERMS):

Metzora will maintain full custody of funds and Client data/information, which may be turned over to authorities in the event of account suspension/closure arising from fraud investigations, AML investigations or violation of Metzora’s Terms (eg. trading with Metzora from a sanctioned country), or if warranted by authorities.