Anti-Money Laundering Policy Brief

Policy Statement

Funded Guru Services - FZCO (trading as "Funded.Guru") is committed to the prevention of money laundering, terrorist financing, and the evasion of sanctions. Consistent compliance with applicable laws and regulations protects the Company's reputation and maintains public confidence in the Funded.Guru brand.

Funded Guru Services - FZCO is a UAE-incorporated free zone company offering simulated trading evaluation programmes and simulated funded account programmes. The Company is not a licensed financial institution, investment firm, brokerage, broker-dealer, custodian, asset manager, payment institution, deposit-taking entity, crypto-asset service provider, or virtual asset service provider, and is not subject to the prudential supervisory regimes applicable to those categories of entity. The Company complies with the AML/CFT obligations set out in UAE Federal Decree-Law No. 20 of 2018 and its implementing regulations to the extent applicable to its activities, and applies the FATF Recommendations and related international standards as a benchmark for its programme. The scope of this Policy extends to Funded Guru Services - FZCO and to any current or future subsidiary or affiliate in which it holds a controlling interest.

Policy Objectives

• To set out the Company's position on money laundering, terrorist financing, and sanctions evasion.
• To explain the compliance duties that every director, officer, and employee is required to meet.
• To guide employees in carrying out their daily activities in a manner consistent with legal requirements.
• To sustain a culture of legal and regulatory compliance throughout the Company.

Definition of Money Laundering

In line with Article 2 of UAE Federal Decree-Law No. 20 of 2018 (the "AML Law"), money laundering is the engagement in any of the following acts while knowing, or having reason to know, that the funds concerned originate from a criminal act:

• Transferring or moving the proceeds, or disposing of the funds, with the intention of concealing or disguising their origin.
• Concealing or disguising the true nature, source, location, or manner of disposal of the proceeds.
• Acquiring, holding, or making use of the proceeds upon receiving them.
• Assisting the person who committed the predicate offence to escape punishment.

Money laundering offences require knowledge that funds derive from criminal activity, including where the perpetrator should have known such origin (a standard which captures wilful blindness and reckless conduct). Failure to report suspected criminality to the UAE Financial Intelligence Unit may give rise to criminal liability independently.

Laws and Regulations

The laws to which Funded Guru Services - FZCO is subject, and with which it complies, include:

• UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations, as amended.
• Cabinet Decision No. 10 of 2019 (Implementing Regulation of the AML Law), as amended.
• Cabinet Decision No. 74 of 2020 on the UAE List of Terrorists and the implementation of UN Security Council sanctions decisions.
• Cabinet Decision No. 58 of 2020 on the Regulation of the Real Beneficiary Procedures.
• Cabinet Decision No. 16 of 2021 on Administrative Fines for AML/CFT violations.
• UAE Federal Decree-Law No. 7 of 2014 on Combating Terrorism Crimes, as amended.
• UAE Federal Decree-Law No. 31 of 2021 issuing the Penal Code.
• UAE Federal Decree-Law No. 38 of 2022 on Criminal Procedures.
• United Nations sanctions adopted into UAE law, and the AML/CFT rules of the Company's free zone authority.

Entities subject to UAE AML/CFT laws are required to adopt a risk-based approach to fulfil their legal obligations, including in customer onboarding and ongoing monitoring. Funded Guru Services - FZCO applies the same risk-based approach across its operations.

Investigatory Powers and Criminal Enforcement

Suspected illicit financial activity in the UAE is reported to the UAE Financial Intelligence Unit (FIU), hosted by the Central Bank of the UAE, via the goAML reporting platform. The Public Prosecution has authority to bring criminal proceedings for AML/CFT offences before the criminal courts. Administrative actions for violations of the AML Law and Regulations are brought by the relevant supervisory authority under Cabinet Decision No. 16 of 2021.

Detection of Unusual or Suspicious Transactions

As a business-to-consumer operator, the Company's transactions consist primarily of individual Access Pass purchases in the typical range of US$52 to US$1440, together with Performance Reward payouts. Every transaction is subject to a risk-based control framework combining automated rule-based screening (covering velocity, geography, value, device, payment instrument, and behavioural anomalies) with risk-tiered manual review. Transactions warranting human review are escalated to the risk management function and, where appropriate, to the Designated Compliance Officer.

Risk Rating

The Company operates a dedicated risk management function responsible for assigning each customer a risk rating (low, medium, or high) on the basis of nationality and residency, occupation, PEP status, sanctions exposure, payment behaviour, and other factors. Due diligence is applied proportionately to the customer's risk rating, with enhanced due diligence applied to higher-risk customers, including PEPs, customers connected to high-risk jurisdictions, and customers requesting cumulative Performance Rewards above thresholds determined from time to time.

Sanctions and Crypto-Asset Compliance

The Company screens all customers and wallet addresses against UN sanctions, the UAE Local Terrorist List established under Cabinet Decision No. 74 of 2020, and the sanctions regimes of OFAC, the EU, the UK, and other relevant authorities, at onboarding and on an ongoing basis. The Company does not accept customers from Restricted Jurisdictions identified in its Terms and Conditions.

Performance Rewards paid in crypto-assets are routed through authorised regulated payment partners and virtual asset service providers (VASPs). Wallet addresses are screened by blockchain analytics providers for sanctions exposure, mixer use, and other indicators of non-compliant activity. Travel Rule originator and beneficiary information is collected and transmitted by the Company's VASP partners as required by applicable law. Funded Guru Services - FZCO is not itself a VASP.

Record Retention

All customer due diligence records, transaction records, sanctions screening records, suspicious transaction reports, training records, and risk assessments are retained securely for a minimum of five (5) years from the end of the business relationship or the date of the relevant record, in line with the AML Law, related regulations, and other applicable retention requirements.

Defences and Penalties

The Regulations do not establish defences specific to money laundering; the general defences under UAE criminal law apply. Where a conviction for a money laundering offence is obtained, the AML Law provides for financial penalties ranging from AED 100,000 to AED 10 million and imprisonment for up to ten (10) years. Administrative fines of up to AED 5 million per violation may be imposed under Cabinet Decision No. 16 of 2021 for failures relating to customer due diligence, monitoring, reporting, or record retention. Additional supervisory measures may include warnings, restriction or suspension of business activities, and removal of responsible directors and senior management.

Company Obligations

• Identify the ML/FT risks arising in the course of its operations.
• Conduct ongoing risk assessments and maintain a documented enterprise-wide risk assessment.
• Maintain internal controls and policies that enable effective management of identified risks.
• Apply customer due diligence, enhanced due diligence, and ongoing monitoring proportionately to risk.
• Implement UN and UAE sanctions and counter-proliferation directives without delay.
• Report suspicious activity to the UAE FIU via goAML.
• Cooperate with the FIU, the Executive Office for Control & Non-Proliferation, the Public Prosecution, and other competent authorities.

Prohibited Relationships

The Company does not engage in correspondent banking relationships and does not establish or continue business with shell banks, shell entities, designated persons under applicable sanctions, persons reasonably believed to be acting on their behalf, or persons whose source of funds or wealth cannot reasonably be verified.

Training

Directors, officers, and employees receive AML/CFT training on induction and at least annually thereafter. Training covers the Company's products and their inherent ML/FT risks, the identification and reporting of suspicious activity, the internal escalation process, the tipping-off prohibition, sanctions and Restricted Jurisdictions, and personal liability under the AML Law. Attendance and content of all training is documented and retained. The Designated Compliance Officer communicates any newly enacted or amended AML/CFT laws, and any update to internal policies or procedures, to relevant staff.

Designated Compliance Officer

The Board of Directors appoints, in writing, a Designated Compliance Officer who serves as the Company's Money Laundering Reporting Officer (MLRO). The Compliance Officer is responsible for the day-to-day operation of the Company's AML/CFT programme, including risk assessment, customer due diligence oversight, transaction monitoring, sanctions screening, suspicious transaction reporting, training, and record retention. The Compliance Officer reports directly to the Board, has authority to file suspicious transaction reports without prior approval from any other officer or director, and is empowered to access all customer records, transaction data, and systems necessary to discharge their duties. The identity of the appointed Compliance Officer is recorded in the Company's internal compliance register and disclosed to competent authorities and material counterparties as required.

Tipping-Off Prohibition

It is a criminal offence under UAE law to disclose to the customer concerned, or to any third party, that a suspicious transaction report has been filed or is being considered, or that an AML/CFT investigation may be undertaken. All directors, officers, and employees are strictly prohibited from tipping off through any channel.

Policy Review

This Policy is reviewed at least annually and on any material change to the Company's business, the applicable legal framework, or the Company's enterprise-wide risk assessment. Amendments require Board approval. This Policy is part of, and should be read together with, the Company's Terms and Conditions and Privacy Policy.

Effective Date: 14 May 2026 — Approval: Board of Directors, Funded Guru Services - FZCO