Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

CoinProp Ltd. (“CoinProp”, “we”, “our”, “us”) is firmly committed to the prevention of money laundering, terrorist financing, fraud, and the evasion of sanctions. We comply with applicable laws in Saint Lucia, Canada, and other jurisdictions where we operate, as well as international best practices including the Financial Action Task Force (FATF) recommendations.

This policy applies to all CoinProp operations, platforms, and subsidiaries, including Afra Digital (Canada), and extends to all entities where we hold ownership interests.

Our AML/KYC framework is designed to:

• Prevent CoinProp’s Services from being used for money laundering, terrorist financing, or other financial crimes.
• Ensure compliance with applicable laws and global sanctions regimes.
• Provide clear procedures for verifying customer identities using Veriff and other approved service providers.
• Establish a risk-based approach to onboarding and ongoing monitoring.
• Train employees to identify and report suspicious activity.

Our AML/KYC measures comply with:

• Saint Lucia Money Laundering (Prevention) Act and related regulations
• Canada Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) (as applicable to Afra Technologies Inc.)
• FATF Recommendations
• UN Sanctions lists and other applicable global sanctions programs
• Applicable AML/CFT obligations in the jurisdictions of our users and service providers



We reserve the right to reject or terminate any application at our discretion.

Money laundering is the process of concealing the origin of funds obtained from criminal activity. This includes:

• Transferring, converting, concealing, or disguising the nature of criminal proceeds
• Assisting in the movement or use of such funds
• Acquiring, possessing, or using such funds while knowing they originated from crime

All customers must undergo identity verification before gaining access to CoinProp’s evaluation or funded accounts. This includes:

• Full name, date of birth, and nationality
• Government-issued photo ID (passport, national ID, or driver’s license)
• Proof of address (utility bill, bank statement, or government correspondence dated within 3 months)
• Biometric facial verification (via Veriff) to match the ID with the applicant
• Sanctions, watchlist, and politically exposed person (PEP) screening

CoinProp reserves the right to request additional documents or re-verify customers at any time.

We assess the risk level of each customer based on factors including:

• Country of residence
• Nature of trading activity
• Sanctions or PEP status
• Adverse media or law enforcement interest

High-risk accounts may be subject to enhanced due diligence (EDD), including:

• Additional identity verification
• Proof of source of funds or wealth
• Ongoing monitoring of transactions

We monitor accounts for suspicious patterns, such as:

• Inconsistent identity or document information
• Attempts to bypass KYC
• Abnormal activity compared to expected trading behavior
• Links to sanctioned entities or individuals

Suspicious activity will be reported to the relevant Financial Intelligence Unit (FIU) in Saint Lucia, Canada, or other applicable jurisdiction.

We securely retain all KYC records, verification results, and transaction history for a minimum of 5 years after account closure, in compliance with applicable laws.

All employees receive AML/KYC training at least annually, including:

• Recognizing suspicious activity
• Reporting procedures
• Updates to AML/CFT regulations
• Use of Veriff and internal compliance tools

CoinProp complies with sanctions programs issued by:

• United Nations Security Council
• Office of Foreign Assets Control (OFAC – USA)
• European Union (EU)
• United Kingdom (UK HMT)
• Other applicable national authorities

We do not conduct business with individuals, entities, or countries subject to relevant sanctions.

CoinProp has appointed a Designated Compliance Officer responsible for:

• Overseeing AML/KYC program implementation
• Ensuring ongoing regulatory compliance
• Coordinating suspicious activity investigations
• Reporting to relevant authorities

Failure to comply with AML/KYC procedures may result in:

• Account suspension or termination
• Reporting to relevant authorities
• Legal and regulatory action