1. Firm Policy

The company is firmly committed to prohibiting and actively preventing money laundering and any activities that facilitate money laundering, terrorist financing, or other criminal activities. This commitment complies with all applicable requirements of the Bank Secrecy Act (BSA) and its implementing regulations.

Our anti-money laundering (AML) policies, procedures, and internal controls are carefully designed to ensure compliance with BSA regulations and FINRA rules. Regular reviews and updates will be conducted to adapt to regulatory and business changes.

2. Providing AML Information

We are committed to not disclosing information requested or obtained by FinCEN unless necessary to comply with information requests. Receipt of National Security Letters (NSL) will be treated with utmost confidentiality. Any Suspicious Activity Reports (SARs) filed following the receipt of an NSL will not reference the NSL’s receipt or existence, focusing solely on the facts and circumstances of the suspicious activity detected.

3. Monitoring Accounts for Suspicious Activity

We will diligently monitor account activity to identify transactions of unusual size, volume, pattern, or type, considering risk factors and red flags appropriate for our business.

Red Flags

Red flags indicating potential money laundering or terrorist financing include but are not limited to:

Potential Red Flags in Customer Due Diligence and Interaction

1. Customers provide unusual or suspicious identification documents that cannot be easily verified or are inconsistent with other statements or documents.

2. Customers are unwilling or refuse to provide complete customer due diligence information.

3. Customers refuse to identify legitimate sources of funds or provide false, misleading, or substantially incorrect information.

4. Customers reside or conduct transactions in jurisdictions known for bank secrecy, tax havens, high-risk areas, or conflict zones.

5. Customers have difficulty describing the nature of their business or lack industry knowledge.

6. Customers have been denied or terminated by other financial service firms.

7. Customers’ legal or mailing address is associated with multiple unrelated accounts or businesses.

8. Customers act as agents for undisclosed principals but are unwilling to provide information.

9. Customers are trust companies, shell companies, or private investment companies unwilling to disclose ownership and potential beneficiaries.

10. Customers are publicly known or alleged to be involved in criminal, civil, or regulatory proceedings.

11. Customers maintain multiple accounts with no apparent business purpose.

12. Accounts opened in the name of entities involved in activities linked to known terrorist organizations.

Other Potential Red Flags

13. Customers express unusual concern about the company’s compliance with government reporting requirements.

14. Customers attempt to dissuade employees from filing required reports.

15. Subpoenas or freeze letters issued by law enforcement regarding customers or accounts.

16. Customers conduct large transactions disproportionate to their known income.

17. Customers propose transactions lacking business sense or clear investment strategy.

18. Securities transactions canceled before maturity without apparent reason.

19. Customers show no concern about transaction costs.

4. AML Record Retention

The AML compliance officer and designated personnel will ensure proper maintenance of AML records and timely submission of SARs as required.

5. Clearing/Introducing Firm Relationships

We will work closely with our clearing firm to detect money laundering activities. Information, records, data, and exception reports will be exchanged as needed to comply with AML laws.

6. Senior Management Approval

Senior management has provided written approval for this AML compliance program, deeming it reasonably designed to achieve and monitor the company’s ongoing compliance with BSA requirements and its implementing regulations.

Effective Date: January 1, 2022

Company: Hong Kong Boda Technology Limited

Location: ROOM A1, 11/F, WINNER BUILDING, 36 MAN YUE STREET, HUNG HOM, KOWLOON, HONG KONG