Anti-Money Laundering (AML) Compliance Program of Aproxy

Our company, Smart Innovation Technology Limited, is firmly committed to preventing money laundering, terrorist financing, and all forms of criminal facilitation. We are dedicated to full compliance with the Bank Secrecy Act (BSA), relevant Hong Kong and international AML regulations, and guidance from appropriate regulatory authorities.

Our AML policies, procedures, and internal controls are carefully designed to ensure full compliance and will be reviewed and updated periodically to reflect changes in applicable laws or the structure of our business.

We will not disclose any information requested by FinCEN or other regulatory bodies unless legally required. If we receive a National Security Letter (NSL), it will be handled with strict confidentiality. SARs will not mention the existence of an NSL but will focus solely on the observed suspicious activity.

We will monitor customer behavior and transactional activity to identify any unusual amounts, frequency, types, or patterns, and will take appropriate action based on our internal risk assessment procedures and industry best practices.

Customer provides unverifiable or suspicious identification.

Customer refuses to provide complete identification, source of funds, or business details.

Customer is from or deals with a high-risk jurisdiction (e.g. tax haven, sanctioned country).

Customer's transactions are inconsistent with declared business activity.

Customer shows unusual concern about AML procedures.

Customer engages in frequent large transactions without clear business rationale.

Law enforcement or regulators issue inquiries or subpoenas related to the customer.

Our AML Compliance Officer and designated staff shall ensure that all relevant records, including customer due diligence (CDD) data, transaction logs, and SAR filings, are maintained for at least five years and made available upon lawful request by authorities.

Where clearing partners or third-party service providers are involved, we will share relevant AML data and reports as required, ensuring joint compliance and avoiding regulatory gaps.

This AML Compliance Program has been reviewed and formally approved by the senior management of Smart Innovation Technology Limited. Management affirms that the program is appropriately designed to ensure continued compliance with the BSA and other applicable AML regulations.