ANTI-MONEY LAUDERING PROCEDURES

Anti-Money Laundering Policy Libra Digital Marketing is committed to the highest standards of Anti-Money Laundering (AML) compliance and requires the management, and employees to follow the following standards.

Anti-Money Laundering Policy Libra Digital Marketing , like most companies providing services within this domain, adheres to the principles and practices of Anti-Money Laundering and actively prevents any actions that aim or facilitate the process of money laundering. AML policy means preventing the use of the company’s services by criminals, with the aim of money laundering, or financing other criminal activity.

Money laundering – the process of converting funds, received from illegal activities (such as fraud, corruption, terrorism, etc.), into other funds or investments that look legitimate to hide or distort the real source of funds

For this purpose, a strict policy on the detection, prevention and warning of the corresponding bodies of any suspicious activities was introduced by the company. Moreover, Libra Digital Marketing has no right to report to clients that law enforcement bodies are informed of their activity. A complex electronic system for identifying every company’s client and conducting a detailed history of all operations was introduced as well.

To prevent money laundering, Libra Digital Marketing neither accepts nor pays cash under any circumstances.

The company reserves the right to suspend any client’s operation, which can be regarded as illegal or, may be related to money laundering in the opinion of the staff.

Company’s procedures Libra Digital Marketing will make sure that it is dealing with a real person or legal entity. Libra Digital Marketing also performs all the required measures in accordance with applicable law and regulations, issued by monetary authorities.

The Anti-Money Laundering policy is being fulfilled within Libra Digital Marketing by means of the following:

• Know Your Customer and Due Diligence

• Know your customer policy and due diligence.

• Monitoring of client activity.

• Record keeping.

Because of the company’s commitment to the AML and KYC policies, each client of the company has to finish a verification procedure. Before LDM starts any cooperation with the client, the company ensures that satisfactory evidence is produced or such other measures that will produce satisfactory evidence of the identity of any customer or counterparty are taken. The company as well applies heightened scrutiny to clients, who are residents of other countries, identified by credible sources as countries, having inadequate AML standards or that may represent a high risk for crime and corruption and to beneficial owners who resides in and whose funds are sourced from named countries.

INDIVIDUAL CLIENTS

During the process of registration, each client provides personal information, specifically: full name; date of birth; origin; complete address, including phone number and city code. A client sends the following documents (in case the documents are written in non-Latin characters: to avoid any delays in the verification process, it is necessary to provide a notarized translation of the document in English) because of the requirements of KYC and to confirm the indicated information:having inadequate AML standards or that may represent a high risk for crime and corruption and to beneficial owners who resides in and whose funds are sourced from named countries.

A high-resolution copy of the first page of local or international passport, where the photo and the signature are clearly seen, or a copy of driver’s license with the same requirements. The indicated documents must be valid at least 6 months from the filing date.

A high-resolution copy of a receipt of utility services payment or bank statement, containing the full client’s name and the actual place of residence. These documents should not be older then 3 months.

CORPORATE CLIENTS

This procedure is performed to establish the identity of the client and to help LDM know/understand the clients and their financial dealings to be able to provide the best services of online trading.

In case the company is unquoted and none of the principal directors or shareholders already has an account with LDM, the official provides the following documents because of the requirements of KYC:

• A high-resolution copy of the certificate of incorporation/certificate;

• An extract from the Commercial Register, or equivalent document, evidencing the registration of corporate acts and amendments;

• Names and addresses of all officers, directors and beneficial owners of the corporate entity;

• A high-resolution copy of Memorandum and Articles of Association or equivalent documents duly recorded with the competent registry;

• Evidence of the company’s registered address and the list of shareholders and directors;

• Description and nature of business (including the date of commencement of the business, products or services provided; and the location of principal business).

This procedure is performed to establish the identity of the client and to help LDM know/understand the clients and their financial dealings to be able to provide the best services of online trading.

Monitoring of client activity

In addition to gathering information from the clients, LDM continues to monitor the activity of every client to identify and prevent any suspicious transactions.

A suspicious transaction is known as a transaction that is inconsistent with the client’s legitimate business or the usual client’s transaction history known from client activity monitoring. LDM has implemented the system of monitoring the named transactions (both automatic and, if needed, manual) to prevent using the company’s services by criminals.

Deposit and withdrawal requirements

All the clients’ operations to deposit and withdraw funds have the following requirements

• In case of bank transfer or transfer from a bank card, the name, indicated during the registration must match the name of the owner of the account/bank card.

• Withdrawing funds from the trading account via the method, which is different from the depositing method, is possible solely after withdrawing the sum, which is equal to the sum of client’s deposits via the method and to the same account used for depositing.

• If the account was credited in the way that cannot be used for funds withdrawal, the funds may be withdrawn to a bank account of the client or any other way may be used, as agreed with the Company with the help of which the Company is able to prove the identity of the account owner.

• If the account has been credited with funds through various payment systems, funds withdrawal shall be made on a pro rata basis commensurate to the size of each deposit.

• In case of depositing via Visa/MasterCard, Wire Transfer, ePayments, the withdrawal of funds, which exceed the sum of the client’s deposits, is possible via any of the following methods: Visa/MasterCard, Wire Transfer, ePayments. In case of depositing via another method, the withdrawal of funds that exceed the sum of the client’s deposits, is possible via any available method, by the client’s choice.