AML Policy · Prevention of Money Laundering and Customer Verification

Introduction and scope

This Anti-Money Laundering Policy applies exclusively to the Services provided directly by TOGO INFINITY LIMITED, specifically to the Services it manages directly or through the intermediaries that provide the services available on the platform.

For the Services of the Authorized Intermediaries, please also refer to the corresponding anti-money laundering policies, available in the relevant section of the Platform.

Regulatory references

Customer due diligence (KYC / KYB)

Before opening an account and accessing THE REAL MONEY services, every customer is subject to the customer due diligence (CDD) procedure, which is mandatory under the applicable AML regulations.

3.1 — KYC for individuals

• a) Valid identity document (national ID card, passport or driving licence).
• b) Proof of address (utility bill, bank statement or official document showing an address) no more than 3 months old.
• c) Tax code or equivalent in the country of residence.
• d) Photograph in "selfie with document" format for biometric verification, taken through the Platform's automated verification system.
• e) Declaration on the source of funds, for transactions exceeding certain thresholds or for the activation of specific Services.

3.2 — KYB for legal entities

• a) Chamber of Commerce certificate or equivalent document evidencing the legal existence and powers of representation.
• b) Articles of association or deed of incorporation.
• c) Identification and verification of all ultimate beneficial owners (UBOs) with a direct or indirect holding of 25% or more.
• d) Full KYC for each UBO and for the legal representative acting on behalf of the company.
• e) Documentation on the nature of the activity carried out and the source of the funds.

3.3 — Enhanced due diligence (EDD)

Where high-risk factors are present, THE REAL MONEY applies enhanced due diligence (EDD) measures. The factors that may trigger it include, among others:

• A customer residing or operating in high-risk countries according to the FATF, EU or CBI lists.
• Transactions of a particularly high amount or with an unusual structure.
• Discrepancies between the declared profile and the transactions actually carried out.
• Alerts generated by automated monitoring systems.

Where additional information is requested, the Company may require supplementary documentation such as tax returns, recent payslips, bank statements, contracts or other documents evidencing the source of the funds. Refusal to provide such documentation will result in the rejection of the application or the suspension of the account.

3.4 — Identification of the ultimate beneficial owner (UBO)

In compliance with the applicable legislation, the Company identifies the Ultimate Beneficial Owner according to the following criteria:

• For legal persons: the natural person who directly or indirectly owns or controls more than 25% of the capital or of the voting rights, or who exercises management control. Where no such person can be identified, the legal representative or senior management.
• For trusts and similar entities: the settlor, the trustee, the protector (if any) and the beneficiaries or class of beneficiaries.

For each ultimate beneficial owner identified, the Company obtains a declaration signed by the legal representative, verifies the identity and carries out a check against the Politically Exposed Persons (PEP) lists and the international sanctions lists. Where there is insufficient information to identify the ultimate beneficial owner, the Company will not proceed to activate the business relationship.

3.5 — Absolute prohibition of anonymous relationships

The Company does not establish or maintain business relationships with anonymous customers, with persons using fictitious identities, with those who refuse to provide the information necessary for verification, or with those who provide false or contradictory information.

If it proves impossible to complete the verification of the customer, TOGO INFINITY LIMITED will refuse to establish the relationship, will not execute transactions and will assess whether there are grounds for filing a suspicious transaction report with the competent authorities, including the Financial Intelligence Unit (FIU) of Ireland.

Ongoing transaction monitoring

The Company continuously monitors the transactions carried out through the Platform in order to identify anomalous behavior or behavior potentially linked to unlawful activities.

4.1 — Periodic profile updates

THE REAL MONEY reserves the right to ask customers to update their data and documentation at any time, in particular where significant changes occur in their transactions or their profile. Customers are required to respond promptly to such requests.

Reporting obligations to the authorities

The Company is required to report to the competent authorities without undue delay where it knows, suspects or has reasonable grounds to suspect that the funds involved are of unlawful origin or are linked to terrorist financing.

5.1 — Competent authorities

Customer obligations and rights

6.1 — Customer obligations

The Company's customer is required to:

• Provide truthful, accurate and up-to-date information during registration and at every stage of the contractual relationship.
• Submit the documentation required under the KYC/KYB procedures within the time limits indicated.
• Immediately notify any significant change in their data (residence, nationality, nature of the business activity, corporate structure for legal entities).
• Not use the Platform or the Services for money laundering, terrorist financing or any other unlawful activity.
• Not provide false or misleading information in order to circumvent the verification procedures.

6.2 — Consequences of non-compliance

Failure to comply with the obligations set out may give rise to:

• Rejection of the application to open an account or to activate one or more services.
• Temporary suspension or permanent closure of the Account.
• A report to the competent authorities where the customer's conduct amounts to suspicious transactions under the AML regulations.

TOGO INFINITY LIMITED is not obliged to provide detailed reasons in cases where this is prohibited or restricted by the applicable anti-money laundering legislation or by the provisions of the competent authorities.

6.3 — Customer rights

The customer has the right to:

• Be informed, clearly and in advance, about the verification procedures they will be subject to and about the documents that may be requested from them.
• Receive a reasoned reply where an account opening application is rejected, except in cases where such communication is prohibited by the AML rules (for example, where a suspicious transaction report exists).
• Exercise their personal data protection rights (access, rectification, erasure, portability) in accordance with the GDPR and the Privacy Policy published on the website, within the limits allowed by AML legislation on data retention.

Data retention and record keeping

The Company retains all documentation collected under the AML/KYC/KYB procedures for a minimum period of 5 years from the end of the contractual relationship with the customer, in compliance with Irish legislation (Criminal Justice Acts 2010-2021) and the applicable European legislation.

Where suspicious transactions are reported to the authorities, the documentation will be retained for a minimum period of 5 years from the date of the report, or for any longer period required by the competent authority.

Data collected for AML purposes is stored and used exclusively for compliance with the regulations in force and is not used for commercial or profiling purposes.

Training and internal governance

8.1 — Anti-Money Laundering and Compliance Officer

THE REAL MONEY has appointed a compliance and anti-money laundering officer responsible for:

• Overseeing the implementation of this AML Policy and regulatory updates.
• Receiving internal reports of suspicious transactions and assessing whether there is an obligation to report them to the authorities.
• Managing relations with the Central Bank of Ireland and the Financial Intelligence Unit on AML matters.
• Ensuring the mandatory periodic training of staff and collaborators.

8.2 — Mandatory training

All employees, contractors and members of the Company receive mandatory training on the prevention of money laundering and terrorist financing at the start of their working relationship and, as a minimum, annually. The training covers:

• Irish and European AML regulations in force and their relevant updates.
• Internal KYC/KYB and due diligence procedures.
• Detection of anomaly indicators and suspicious transactions.
• Internal reporting procedure to the AML/Compliance officer.
• Specific obligations relating to advisory services (MiFID II).

8.3 — Periodic review

This Policy is subject to review at least annually, or in the event of significant regulatory changes, by the Anti-Money Laundering and Compliance Officer, with the approval of the Board of Directors. The updated version is always available on the Platform.

Summary: what we ask the customer for and why

To make the process as clear as possible, the documentation that the Company may request and the regulatory reason for each request are set out below: