KYC/AML COMPLIANCE POLICY

KIBOV PTE. LTD. — ANTI-MONEY LAUNDERING AND KNOW YOUR CUSTOMER FRAMEWORK

1. Purpose and scope

This policy establishes the Anti-Money Laundering (AML) and Know Your Customer (KYC) framework for KIBOV Pte. Ltd. (“KIBOV”, “the Company”), a Singapore-incorporated entity operating a cross-border real-world asset tokenization platform on the Base Layer 2 network.

This policy applies to all individuals and entities seeking to subscribe to credit pool instruments offered through the KIBOV platform, and to all employees, contractors, and third-party service providers engaged by the Company.

2. Regulatory framework

KIBOV’s compliance framework is designed to align with:

• Payment Services Act 2019 (Singapore) — digital payment token services provisions
• MAS Notice PSN02 on Prevention of Money Laundering and Countering the Financing of Terrorism
• Financial Action Task Force (FATF) Recommendations, including the Travel Rule for virtual asset service providers
• Applicable laws in originator jurisdictions: UU PDP (Indonesia), DPA (Philippines), LFPDPPP (Mexico)

3. Customer due diligence (CDD)

3.1 Individual investors (retail / accredited)

• Government-issued photo identification (passport or national ID)
• Proof of residential address (utility bill or bank statement, dated within 3 months)
• Self-declaration of accredited investor status where applicable
• Source of funds declaration for subscriptions exceeding USD 50,000

3.2 Institutional investors

• Certificate of incorporation and constitutional documents
• Register of directors and beneficial owners (UBO declaration for over 25% ownership)
• Board resolution authorizing the subscription
• Audited financial statements (most recent fiscal year)
• AML compliance officer contact details

3.3 Enhanced due diligence (EDD)

EDD is triggered when:

• The investor is a Politically Exposed Person (PEP)
• The jurisdiction of incorporation or residence is classified as high-risk by FATF
• The transaction pattern deviates significantly from the investor’s stated profile
• Adverse media screening returns material findings

4. Wallet screening and transaction monitoring

4.1 On-chain screening

All wallet addresses are screened against:

• OFAC Specially Designated Nationals (SDN) List
• Chainalysis sanctions oracle (on-chain, real-time)
• Internal watchlist maintained by the compliance team

4.2 Ongoing transaction monitoring

• Automated monitoring of subscription and withdrawal patterns
• Threshold alerts for single transactions exceeding USD 100,000
• Velocity alerts for multiple transactions within 24-hour windows
• Cross-referencing with KYT (Know Your Transaction) service providers

5. Suspicious activity reporting

Where the compliance team identifies grounds for suspicion of money laundering or terrorist financing:

• An internal Suspicious Transaction Report (STR) is filed within 24 hours
• The relevant Suspicious Transaction Reporting Office (STRO) in Singapore is notified as required under applicable law
• The investor’s account is frozen pending investigation

6. Record retention

All KYC documentation, transaction records, and compliance decisions are retained for a minimum of five (5) years following the termination of the business relationship, in accordance with MAS requirements.

7. Training and awareness

All personnel with customer-facing responsibilities receive AML/CFT training upon onboarding and annually thereafter. Training records are maintained by the compliance function.

8. Policy review

This policy is reviewed and updated at minimum annually, or upon material changes in the regulatory landscape.

Compliance Officer: [Name withheld — to be appointed]
Contact: compliance@kibov.com

This document is an institutional draft for operational clarity. It does not constitute legal advice. Final obligations are governed by executed agreements, applicable law, and counsel-approved policies.