KYC POLICY OF SUNWIN

The Company adheres to and complies with “Know your customer” principles, which aim to prevent financial crime and money laundering through client identification and due diligence.

WE RESERVE THE RIGHT TO:

• at any time request any KYC documentation we consider necessary to establish and verify the identity and location of a user on Website;

• restrict access to the service, as well as payments or withdrawals, until the user’s identity has been sufficiently verified, or for any other reason at our sole discretion, where such discretion is exercised in line with the applicable legal framework. We apply a risk-based approach and conduct strict due diligence checks and ongoing monitoring of all clients, customers, and transactions.

In accordance with anti–money laundering regulations, we apply three levels of due diligence, depending on the risk level, the type of transaction, and the type of customer:

SDD (Simplified Due Diligence) — applied in cases of extremely low-risk transactions that do not reach the applicable thresholds;

CDD (Customer Due Diligence) — the standard level of due diligence, applied in most cases for customer identification and verification;

EDD (Enhanced Due Diligence) — applied to high-risk customers, large transactions, or other specific higher-risk situations.

Separately, and in addition to the above, whenever a user requests a withdrawal of any amount on Website, or attempts, or completes a transaction that is considered suspicious, such user is required to complete the full KYC procedure.

During this procedure, the user must provide certain basic personal details and upload the requested verification documentation.

1. A copy of a valid government-issued photo ID (in certain cases, both front and back, depending on the

   document type). The name and other personal details shown on the ID must match the information provided in your application, and the holder must be over 18 years of age. The document must be clear and legible and include the individual’s signature. All text and images on the ID must be easily readable. The ID must remain valid for at least the next three (3) months. In some situations, we may additionally request a copy of both the front and back sides of the ID document, depending on the specific type of ID submitted. Acceptable forms of government-issued photo ID include, without limitation, passports, national identity cards, and driver’s licences. Failure to provide a valid government-issued photo ID meeting these requirements may lead to delays in processing your application or may prevent completion of the KYC verification process.

2. A selfie of the user holding their ID document. As part of our Know Your Customer (KYC) procedures, you are required to submit a selfie in which you are holding your government-issued photo ID. The selfie must be clear and well-lit so that both your face and the ID can be easily identified. The government-issued photo ID must be clearly visible in the selfie, with all text and images on the ID easily readable. Your face must be fully visible and not obstructed in any way. You should avoid wearing sunglasses, hats, or any other accessories that may cover or obscure your face. The selfie should reflect your current appearance and, ideally, should be taken within the last three (3) months to ensure accurate identity verification. The background of the selfie should be neutral and not distracting, so the focus remains on you and the ID. Failure to provide an acceptable selfie that meets these requirements may result in a delay in processing your application or the inability to complete the KYC verification process.

3. Proof of residence (bank statement / utility bill). As part of our Know Your Customer (KYC) process, you are required to provide valid proof of residence. Acceptable documents include, in particular, a bank statement or a utility bill. The document must clearly show your full name and residential address, which must correspond to the information provided in your application. The proof of residence must be dated within the last three (3) months; documents older than this may not be accepted.

   The document must be clear and legible. All text and images must be easily identifiable, and the document must not be damaged, altered, or obscured.

   Acceptable forms of proof of residence include:

   • bank statements (issued by a recognised financial institution);

   • utility bills (including, for example, electricity, water, gas, or internet bills).

     RESTRICTED COUNTRIES FOR DOCUMENT SUBMISSION

     As part of our Know Your Customer (KYC) process, we regret to inform you that we cannot accept documents from users residing in the following restricted countries:

     • Austria

     • France and its territories

     • Germany

     • Netherlands and its territories

     • Spain

     • Union of Comoros

     • United Kingdom

     • USA and its territories

     • All FATF Blacklisted countries

     • Sanctioned countries such as Russia and Belarus

     • Any other jurisdictions deemed prohibited by the Anjouan Offshore Financial Authority.

If you are a resident of any of the above-mentioned countries, we will not be able to process your application. We appreciate your understanding in this matter.