1. Introduction

This AML/CFT policy outlines the measures that our company takes to prevent
money laundering and terrorist financing. through our crypto, gift card and bill
payment services.
We are committed to complying with all applicable laws and regulations, including
anti-money laundering (AML) and countering the financing of terrorism (CFT) laws.
This policy applies to all employees, contractors, and agents who work for or on
behalf of our company.

2. Scope

This policy applies to all individuals and organizations acting on behalf of Astro
Digital management Limited (“Astro”). This includes employees, contractors, and
agents of Astro working on behalf of Astro – jointly referred to as “Astro
representatives”. The Policy also applies to all customers and users of our platform.

3. Risk Assessment

We have conducted a risk assessment of our business and identified the following
risks that are relevant to our operations:
 Cryptocurrency transactions that can be used for money laundering and
terrorist financing.
 Gift cards that can be used for money laundering and terrorist financing.
 Transactions involving high-risk countries or politically exposed persons
(PEPs)
 Transactions that involve large sums of money.
We will periodically review and update our risk assessment to ensure it remains
current and accurate.

4. Know Your Customer (KYC)

We will perform KYC on all customers in accordance with applicable laws and
regulations. KYC will be performed at the time of account opening and on an ongoing
basis. KYC measures will include:
 Verifying the customer's identity using reliable and independent sources
 Collecting and verifying information about the customer's source of funds and
the purpose of the transaction
 Conducting ongoing monitoring of the customer's transactions and activity to
ensure they are consistent with the customer's known source of funds and the
intended purpose of the account.

5. Transaction Monitoring

We will monitor all transactions for suspicious activity.
We will use automated tools and manual reviews to detect and investigate suspicious
activity.
We will file suspicious activity reports (SARs) with the appropriate authorities when
necessary.

6. Record-Keeping

We will maintain records of all customer and transaction data as required by law.
Records will be kept confidential and securely stored. The records include:
 Customer identification and verification information
 Transaction details, including the amount, currency, and date of the
transaction
 Suspicious activity reports and other relevant documentation

7. Training and Awareness

We will provide regular training to employees, contractors, and agents on AML/CFT
policies and procedures. Training will be provided on an ongoing basis to ensure that
all staff members are aware of changes in the risk landscape and applicable laws
and regulations.
We will also raise awareness among our customers about the risks of money
laundering and terrorist financing.

8. Compliance Oversight

We will appoint a designated AML/CFT compliance officer to oversee our compliance
with this policy and all applicable laws and regulations.
The compliance officer will have the authority to take appropriate action to ensure
compliance.

9. Reporting and Escalation

Astro encourages openness and transparency. Any employee, contractor, or agent
who suspects or observes potential money laundering or terrorist financing must
report it to the compliance officer immediately.
The compliance officer will escalate any potential violations to senior management
and, if necessary, to the appropriate authorities..

10. Misconduct and Sanctions

Any violation of the terms in this Policy by any Astro representative may be subject to
disciplinary action, and in extreme cases to immediate termination of employment
and/or a claim for payment of a damage. The same applies to any Astro
representative knowing about any past or potential violations and failing to report
those accordingly.
If employees and affiliates knowingly deceive and obstruct investigations, their action
may be subject to disciplinary proceedings, such as termination of the contract and
discharge and/or paying a penalty fine.
If Third Party agents violate the terms of the Policy, know of any misconduct and fail
to report to Astro and distort investigations purposefully, their contract may be subject
to termination.

11. Other Astro Policies

This Policy is furthermore complementary to all other existing Astro policies and does
not interfere with any of their contents

12. Review and updates

Astro takes money laundering and terrorist financing seriously and is committed to
implementing appropriate measures to prevent these illegal activities from taking
place through our platform. We will periodically review and update this policy to
ensure it remains current and effective.
Any changes to this policy will be communicated to all employees, contractors, and
agents who work for or on behalf of our company.