LAST UPDATED 11 AUGUST 2025

AML & CFT Policy

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AML & CFT Policy

Contents

1. Introduction...................................................................................................................................................................................................3

2. Scope And Purpose Of Anti Money Laundering Policy..............................................................................................................3

3. Money Laundering......................................................................................................................................................................................3

4. Key Principles...............................................................................................................................................................................................4

5. Customer Due Diligence..........................................................................................................................................................................5

6. Natural Persons...........................................................................................................................................................................................6

7. Corporate Person........................................................................................................................................................................................7

8. Inquiry..............................................................................................................................................................................................................7

AML & CFT Policy

Terms and Conditions

Last updated 11 AUGUST 2025

AML & CFT Policy

1. Introduction

1.1. It is the Policy of babaoption.com and its affiliates (hereinafter referred to as the “Company”) to prohibit

and actively pursue the prevention of money laundering and any activity that facilitates money laundering

or the funding of terrorist or criminal activities. The Company requires its officers, employees, and

affiliates to adhere to these standards in preventinguse of its products and services for money

laundering purposes.

1.2. The Company does not tolerate money laundering and supports the fight against money launderers.

2. Scope And Purpose Of Anti Money Laundering Policy

2.1. The Company determines the identity of the beneficialownership of all its clients’ accounts and does

not open or maintain such accounts, unless it is satisfied of this requirement, as stipulated in the AML

Act and the legislative requirements. It has established procedures to obtain appropriate evidence of

client identity and maintains adequate records of client identity and transactions involved in such a

manner as to assist, if necessary, in the investigation of criminal offences.

2.2. The Company has policies in place to deter people from laundering money in relation to the following:

•Client identification and Client due diligence;

•maintaining records of identification information;

•Internal reporting of suspicious transactions to the internal anti-money laundering compliance officer;

•Internal control, risk assessment and risk management in order to prevent money laundering and

terrorist financing;

•Detailed examination of each transaction which by its nature maybe considered to be particularly

vulnerable to be associated with money laundering offences or terrorist financing and in particular

complex or unusually large transactions and all other unusual patterns of transactions which have no

apparent economic or visible lawful purpose;

3. Money Laundering

3.1.Money laundering occurs when funds from an illegal/criminal activity are moved through the financial

system in such a way as to make it appear that the funds have come from legitimate sources.

3.2.Money Laundering usually follows three stages:

AML & CFT Policy

Terms and Conditions

Last updated 11AUGUST 2025

•firstly, cash or cash equivalents are placed into the financial system

•secondly, money is transferred or moved to other accounts (e.g. futures accounts) through a series of

financial transactions designed to obscure the origin of the money (e.g. executing trades with little or

no financial risk or transferring account balances to other accounts)

•and finally, the funds are re-introduced into the economy so that the funds appear to have come from

legitimate sources (e.g. closing a futures account and transferring the funds to a bank account).

3.3.Trading accounts are one vehicle that can be used to launder illicit funds or to hide the true owner of the

funds. In particular, a trading account can be used to execute financial transactions that help obscure

the origins of the funds.

4. Key Principles

4.1.The Company reserves the right to refuse to process a transfer of funds at any stage if it believes it to

be connected in any way to criminal activities or money laundering.

4.2.The Company is obliged to report all suspicious transactions and is prohibited from informing the client

that they have been reported for suspicious account activity. Account misuse may result in criminal

prosecution.

4.3.Where there is suspicion that the source of funds may be criminal or that a client may be involved in

criminal activity, the Company shall follow established procedures for assessing the evidence and

determining what course of action should be pursued.

4.4.The Company shall keep records of reports made by their staff and of reports made to the Supervisory

Authority.

4.5.In accordance with theAML Act, theCompany establishes the identity and verify theidentity of any client

of the Company by requiring the client to produce an identification record or such other reliable,

independent source document as part of the due diligence process.

4.6.The Company shall duly apply Client identification procedures and Client due diligence measures in the

following cases:

•when establishing a business relationship;

•when carrying out transactions that exceed predefined amount, whether the transaction is carried

out in a single operation or in several operations which appear to be linked;

•when there is a suspicion of money laundering or terrorist financing, regardless of the amount of

the transaction in the provision of the relevant Investment and Ancillary Services;

•when there are doubts about the veracity or adequacy of previously Client identification data;

AML & CFT Policy

Terms and Conditions

Last updated 11AUGUST 2025

•in the case of persons trading in goods, when carrying out occasional transactions in cash

amounting to predefined amount or more, whether the transaction is carried out in a single

operation or in several operations which appear to be linked;

•if a client or beneficial owner is a politically exposed person, and if so, shall:

adequately identify and verify his identity as set out in this section;

obtain the approval of senior management before establishing a business relationship with

the politically exposed person;

take reasonable measures to establish the source of funds and source of property;

conduct regular enhanced monitoring of the business relationship

4.7.In the context of the above measures, the Company is not to be required to accept a person as its Client

until all documentation it requires has been received by the Company, properly and fully completed by

such person and all internal checks (including without limitation all anti-money laundering Client

identification and due diligence checks) have been duly satisfied.

4.8.It is further understood that the Company reserves right to impose additional due diligence requirements

to accept Clients residing in certain countries where the risk of money laundering may be higher.

4.9.During the Client identification and due diligence checks the Company shall apply processes to verify

the Client’s identity for which photo identification information will be required from the Client. In certain

circumstances the Company may require this information to be authenticated by an appropriate third

party.

4.10.The Company reserves the right to review and/or amend its Anti-Money Laundering Policy, at its sole

discretion, whenever it deems fit or appropriate.

4.11.These guidelines have been implemented to protect the Company and its clients.

5. Customer Due Diligence

5.1.Due Diligence procedure is an essential part of the AML Policy. Each time when entering into a business

relationship with a client, the Company will apply Customer Due Diligence measures.

5.2.These measures will be applied before any financial transactions or paying any money to the third party.

5.3.The application of such measures is important for the prevention of money laundering as it allows to

know the customers.

5.4.If there is a lack of satisfactory evidence that the client is acting in good conscience or the client’s

documentation is not valid, or there is any other risk of entering into a business relationship with that

AML & CFT Policy

Terms and Conditions

Last updated 11AUGUST 2025

client, the Company will not proceed with any further business with that client.

5.5.Customer Due Diligence procedures will be brought to the knowledge of all relevant employees.

5.6. The process consists of several steps. Initially, the customer’s identity identification and verificationtake

place. Using reliable sources of information, the Company will make sure that the customer is a real

person (if natural person) or existing legal entity (if legal person) as well as ensure that the client is who

he claims to be. If applicable, the Company will also conduct a beneficial owner identity identification

and verification. Further, the nature and purpose of the business relationship will be assessed. Eventually,

the continuous monitoring of transactions of the client will be ensured.

5.7.The Company will always check whether the documents submitted for Due Diligence are up-to-date and

valid.

6. Natural Persons

6.1.In Due Diligence process of individual customers, official identity documents will be accepted as

appropriate documents evidencing the identity of thecustomer. Official identitydocuments must be

current and valid, and bear a photograph of the client.

6.2.During the identification process of the individuals, the Company will collect the following:

•name and surname;

•residential address;

•date and place of birth;

•nationality;

•occupation, pubic position held;

•as the collected identity information must be verified, the Company will rely upon the following

documents;

•passport;

•national identity card;

•driving license;

6.3.For verification of the residential address, the Company will rely upon:

•a recent utility bill issued;

•a recent bank or credit card statement dated;

•a recent bank reference;

AML & CFT Policy

Terms and Conditions

Last updated 11AUGUST 2025

7. Corporate Person

7.1.Due Diligence process of corporate clients requires to verify the existence, good standing of that legal

entity and check whether the persons behind that legal entity are authorized to act on its behalf.

7.2.During the identification process of the corporate customers, the Company will collect the following:

•name of the company;

•registration number of the company;

•date of registration of the company;

•address of the registered office and place of business;

•directors and beneficial owners of the company;

•nature and purpose of business.

•During the verification process of corporate clients, the Company will rely upon:

•certificate of incorporation or registration (certified);

•extract from the Commercial Register of the country of incorporation;

•certificate of incumbency listing the current directors;

•memorandum, statutes, articles of association or other documents which confirm the authority of

respective officers;

8. Inquiry

8.1.For questions/comments regarding these guidelines, please direct your questions to the Company’s

Compliance Department: compliance@babaoption.com.