Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

CoinProp Ltd. (“CoinProp”, “we”, “our”, “us”) is firmly committed to the prevention of money laundering, terrorist financing, fraud, and the evasion of sanctions. We comply with applicable laws in Saint Lucia, Canada, and other jurisdictions where we operate, as well as international best practices including the Financial Action Task Force (FATF) recommendations.

Two entities play distinct roles in this framework, and this policy covers both sides of the money flow:

• Afra Digital, a trade name of Barefoot Enterprises Ltd. (Canada), collects the fee for platform access and operates identity verification. Its responsibilities cover the inbound flow: screening purchasers against the sanctions programs listed in Section 10, verifying identity through Veriff, and managing payment fraud and chargeback risk, in each case in accordance with Canadian law (including the PCMLTFA) as applicable to it.
• CoinProp Ltd. (Saint Lucia) operates the evaluation and funded-stage programs and pays any discretionary rewards. Its responsibilities cover the outbound flow: screening reward recipients before any payment is made, paying rewards in USDC from its own designated wallet with no intermediary, and reporting suspicious activity as described in Section 7.

References to “we” in the remainder of this policy are to CoinProp Ltd., except where a responsibility is expressly identified as Afra Digital’s. This policy applies to all CoinProp operations and platforms.

Our AML/KYC framework is designed to:

• Prevent CoinProp’s Services from being used for money laundering, terrorist financing, or other financial crimes.
• Ensure compliance with applicable laws and global sanctions regimes.
• Provide clear procedures for verifying customer identities using Veriff and other approved service providers.
• Establish a risk-based approach to onboarding and ongoing monitoring.
• Train employees to identify and report suspicious activity.

Our AML/KYC measures comply with:

• Saint Lucia Money Laundering (Prevention) Act and related regulations
• Canada Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) (as applicable to Afra Digital, a trade name of Barefoot Enterprises Ltd.)
• FATF Recommendations
• UN Sanctions lists and other applicable global sanctions programs
• Applicable AML/CFT obligations in the jurisdictions of our users and service providers

We reserve the right to reject or terminate any application at our discretion.

Money laundering is the process of concealing the origin of funds obtained from criminal activity. This includes:

• Transferring, converting, concealing, or disguising the nature of criminal proceeds
• Assisting in the movement or use of such funds
• Acquiring, possessing, or using such funds while knowing they originated from crime

When verification is required. Identity verification is not required in order to purchase an evaluation or to trade a simulated evaluation account. It must be completed and valid before a simulated funded account is activated, before any reward payout is processed, and before affiliate or referral earnings can be withdrawn. Funded-account trading and all payouts remain unavailable until verification is complete.

Screening at the point of purchase. Eligibility screening applies from purchase onwards. Purchasers confirm that they do not ordinarily reside in a restricted jurisdiction and are not subject to the sanctions programs listed in Section 10, and Afra Digital screens purchases against those programs as described in Section 1.

Verification is handled through Veriff and covers:

• Full name, date of birth, and nationality
• Government-issued photo ID (passport, national ID, or driver’s license)
• Proof of address (utility bill, bank statement, or government correspondence dated within 3 months)
• Biometric facial verification (via Veriff) to match the ID with the applicant
• Sanctions, watchlist, and politically exposed person (PEP) screening

If identity verification is rejected, or verification determines that the participant was not eligible at the time of purchase, all of that participant’s active evaluation purchases are refunded in full and platform access is closed.

CoinProp reserves the right to request additional documents or re-verify customers at any time.

We assess the risk level of each customer based on factors including:

• Country of residence
• Nature of trading activity
• Sanctions or PEP status
• Adverse media or law enforcement interest

High-risk accounts may be subject to enhanced due diligence (EDD), including:

• Additional identity verification
• Proof of source of funds or wealth
• Ongoing monitoring of transactions

We monitor accounts for suspicious patterns, such as:

• Inconsistent identity or document information
• Attempts to bypass KYC
• Abnormal activity compared to expected trading behavior
• Links to sanctioned entities or individuals

Suspicious activity will be reported to the relevant Financial Intelligence Unit (FIU) in Saint Lucia, Canada, or other applicable jurisdiction.

We securely retain all KYC records, verification results, and transaction history for a minimum of 5 years after account closure, in compliance with applicable laws.

All employees receive AML/KYC training at least annually, including:

• Recognizing suspicious activity
• Reporting procedures
• Updates to AML/CFT regulations
• Use of Veriff and internal compliance tools

CoinProp complies with sanctions programs issued by:

• Global Affairs Canada (consolidated autonomous sanctions list, SEMA and JVCFOA)
• United Nations Security Council
• Office of Foreign Assets Control (OFAC – USA)
• European Union (EU)
• United Kingdom (UK HMT)
• Other applicable national authorities

We do not conduct business with individuals, entities, or countries subject to relevant sanctions.

CoinProp has appointed a Designated Compliance Officer responsible for:

• Overseeing AML/KYC program implementation
• Ensuring ongoing regulatory compliance
• Coordinating suspicious activity investigations
• Reporting to relevant authorities

Failure to comply with AML/KYC procedures may result in:

• Account suspension or termination
• Reporting to relevant authorities
• Legal and regulatory action