Anti-Money Laundering & KYC Policy

In short: This policy describes how OPO detects and prevents money laundering and terrorism financing. It explains the risk-based approach OPO applies to countries, customers and services; the identity documents required under KYC (a valid passport, ID or driving licence, plus proof of residence no older than six months); how account activity is monitored; and that records are kept for at least five years after an account closes. This summary is for convenience only; the numbered terms below are binding.

1. Introduction This document describes Opo Group LLC's policy and commitment to the detection and prevention of any money laundering or terrorism financing activity within the products and services offered by Opo Group LLC to its customers.
2. Definition "Money Laundering" is the participation in any transaction that seeks to conceal or disguise the nature or origin of funds derived from illegal activities such as, for example, fraud, corruption, organized crime, or terrorism etc. Predicate offences for money laundering are defined by national law. The money laundering process consists of three stages:

Placement. Physically depositing cash into banks and non-bank financial institutions such as currency exchanges; converting cash into other financial instruments such as by purchasing monetary instruments (travelers' checks, payment orders); or using cash to purchase high-value goods that can be resold. Launderers often seek to deposit cash into banks in countries with low financial market regulation demands and then transfer these funds to banks in regulated environments as "clean". Smurfing — a form of Placement where the launderer makes many small cash deposits instead of a large one to evade local regulatory reporting requirements applicable to cash transactions.

Layering. Separating the proceeds of criminal activity from their source using layers of financial transactions (multiple transfers of funds among financial institutions, early surrender of an annuity without regard to penalties, cash collateralized loans, L/Cs with false invoices/bills of lading, etc.) to disguise the origin of the funds, disrupt any audit trail, and provide anonymity. Launderers want to move funds around, changing both the form of the funds and their location to make it more complicated for law enforcement authorities to trace "dirty" money.

Integration. Placing the laundered proceeds back into the economy in such a way that they re-enter the financial system as apparently legitimate funds.

This Policy is supported by a set of programs covering the implementation of the following areas:

The adoption of a risk-based approach. Know Your Client (KYC) Policy and Customer Due Diligence; Customer activity monitoring; Record Keeping. 3. The Adoption of a Risk-Based Approach Identification of the money laundering risks of customers and transactions allows Opo Group LLC to determine and implement proportionate measures to control and mitigate these risks. The risk criteria used are the following: 4. Country Risk In conjunction with other risk factors, country risk provides useful information as to potential money laundering risks. Factors that may result in a determination that a country poses a heightened risk include:

Countries subject to sanctions, embargoes, or similar measures. Countries identified by the Financial Action Task Force ("FATF") as noncooperative in the fight against money laundering or identified by credible sources as lacking appropriate money laundering laws and regulations. Countries identified by credible sources as providing funding or support for terrorist activities. 5. Customer Risk There is no universal consensus as to which customers pose a high risk, but the below listed characteristics of customers have been identified with potentially heightened money laundering risks:

Armament manufacturers. Cash intensive business. Unregulated charities and other unregulated "non-profit" organizations. 6. Services Risk Determining the money laundering risks of services should include a consideration of such factors as services identified by regulators, governmental authorities or other credible sources as being potentially high risk for money laundering. 7. Know Your Customer and Customer Due Diligence Opo Group LLC is an online operating brokerage company and therefore business relationships between the company and its customers are not established on a face-to-face basis. For customer identification purposes Opo Group LLC uses electronic data brokers (linked with other in-house checks e.g., identifying duplicate accounts, confirming ownership of bank accounts etc.) to provide identity verification. This will be used to determine and document the identity of customers to obtain background information on customers as well as the purpose and intended nature of their business to us.

Opo Group LLC shall request from the client upon commencement of the business relationship a valid identification document such as Passport – ID – Driving licence, and proof of residence such as a utility bill (not exceeding 6 months), to check and verify the client's identity. During the business relationship Opo Group LLC can request additional documentation or information from the client to verify their identity and the nature of the business.

Opo Group LLC shall obtain and document any additional customer information, commensurate with the assessment of the money laundering risk, using the Risk Based Approach.

Opo Group LLC shall identify whether the customer is acting on behalf of another natural person or legal entity as trustee, nominee, or professional intermediary. In such cases an obligatory precondition of customer service is receipt of satisfactory evidence of the identity of any intermediaries and of the persons upon whose behalf they are acting, as well as the nature of the trust arrangements in place. 8. Customer Activity Monitoring In addition to conducting initial customer due diligence, it is Opo Group LLC policy to continue to monitor customer activity with a view to identifying any suspicious (or fraudulent) behavior. The system of monitoring that has been implemented relies on both automated monitoring and, where appropriate, manual monitoring of transactions by the staff of Opo Group LLC and any outsourced service provider. A series of status fields has been applied to customer accounts indicating their profile within the system, which assists automated monitoring. Opo Group LLC has implemented a regulatory and legally compliant suspicious activity reporting process and procedure that will enable all staff to make a report to the Money Laundering Reporting Officer (MLRO) where they know, or they suspect, or they have reasonable grounds for knowing or suspecting that a person is engaged in money laundering or terrorist financing. This includes three stages to this process:

All personnel must be diligent in monitoring for any unusual or suspicious transactions/activity. The reporting of suspicious transactions/activity must comply with the laws/regulations of the respective jurisdiction. The Money Laundering Reporting Officer (MLRO) must be informed about all suspicious transactions/activity monthly. 9. Record Keeping Records must be kept of all documents obtained for the purpose of customer identification (KYC policy requirements) and all data of each transaction, as well as other information related to money laundering matters, in accordance with the applicable anti-money laundering laws/regulations. That includes files on suspicious activity reports, documentation of AML account monitoring, etc. Those records must be kept for a minimum of 5 years after the closing of the account.