Introduction

Kweeq Technologies Inc. is committed to preventing money laundering and terrorist financing activities through robust anti-money laundering (AML) practices. As a payment platform serving residents of Canada, Kweeq adheres to all relevant laws and regulations, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and the guidelines issued by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

Purpose

This AML policy outlines Kweeq’s framework for detecting, preventing, and reporting money laundering and terrorist financing activities. It establishes procedures and controls to ensure compliance with legal and regulatory requirements, protecting Kweeq, its customers, and the financial system from the risks associated with illicit activities.

Scope

This policy applies to all employees, officers, and directors of Kweeq, as well as any third parties acting on behalf of Kweeq. It covers all products and services offered by Kweeq to residents of Canada.

AML Program Components

1. Customer Due Diligence (CDD)

Kweeq has implemented comprehensive customer due diligence measures to verify the identity of all customers and businesses signed up to Kweeqpay. These measures include:

• Identity Verification: Collecting and verifying customer information, such as name, address, date of birth, and identification documents.
• Enhanced Due Diligence (EDD): Applying additional scrutiny to high-risk customers, transactions, or business relationships.
• Ongoing Monitoring: Continuously monitoring customer transactions to identify suspicious activities and ensure that customer information remains up to date.

2. Record Keeping

Kweeq maintains detailed records of all transactions, customer information, and due diligence measures for a minimum of five years, as required by law. These records are stored securely and made available to regulatory authorities upon request.

3. Reporting Suspicious Transactions

Kweeq has established procedures for identifying and reporting suspicious transactions to FINTRAC. Employees are required to promptly report any transactions that raise suspicion of money laundering or terrorist financing to the designated AML Compliance Officer (AMLCO).

4. AML Compliance Officer (AMLCO)

Kweeq has appointed an AML Compliance Officer responsible for overseeing the implementation and enforcement of this AML policy. The AMLCO’s duties include:

• Developing and maintaining the AML program.
• Conducting regular risk assessments.
• Ensuring employee training and awareness.
• Reviewing and submitting suspicious transaction reports (STRs) to FINTRAC.
• Serving as the primary point of contact with regulatory authorities.

5. Employee Training and Awareness

Kweeq provides ongoing AML training to all employees to ensure they understand their responsibilities under this policy and can recognise and report suspicious activities. Training covers:

• The basics of money laundering and terrorist financing.
• Relevant legal and regulatory requirements.
• Kweeq’s AML policies and procedures.
• Identifying and reporting suspicious transactions.

6. Risk Assessment

Kweeq conducts regular risk assessments to identify and mitigate potential money laundering and terrorist financing risks associated with its products, services, customers, and geographic locations. The risk assessment informs the development and enhancement of AML controls and procedures.

7. Internal Controls and Audits

Kweeq has implemented robust internal controls to ensure compliance with this AML policy and applicable laws. Regular audits are conducted to assess the effectiveness of the AML program and identify areas for improvement.

Kweeq is dedicated to maintaining the highest standards of integrity and compliance in its operations. By adhering to this AML policy, Kweeq aims to prevent money laundering and terrorist financing, protecting its customers and the broader financial system. All employees, officers, and directors of Kweeq are expected to fully comply with this policy and contribute to its effective implementation.

For any questions or further information regarding this AML policy, please contact the AML Compliance Officer at info@kweeq.com

Note: This AML policy is subject to periodic review and updates to ensure ongoing compliance with legal and regulatory changes.

Last Updated: June 2025