AML & KYC Policy

socialmediaboost.it.com is committed to preventing money laundering, terrorist financing, sanctions evasion and other financial crime. This Anti-Money Laundering (AML) and Know-Your-Customer (KYC) Policy sets out the controls we operate to identify, monitor and, where appropriate, report suspicious activity in relation to any customer, transaction or counterparty of the socialmediaboost.it.com service.

This policy applies to every socialmediaboost.it.com customer worldwide, to every payment method we accept, and to every employee, contractor and agent acting on our behalf.

We align our program with the following widely-recognised frameworks and, where applicable, local laws in the jurisdictions we serve:

• Financial Action Task Force (FATF) 40 Recommendations
• EU Anti-Money Laundering Directives (AMLD 4, 5 and 6)
• United States Bank Secrecy Act (BSA) and USA PATRIOT Act
• UK Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended)
• Reserve Bank of India — Master Direction on KYC (as amended)
• State Bank of Pakistan — AML/CFT Regulations for Financial Institutions
• Bangladesh Bank — Guidelines on Prevention of Money Laundering
• Bangko Sentral ng Pilipinas — AML/CFT Rules

Every customer completes Customer Due Diligence before any withdrawal or refund is processed:

1. Identity verification. Full legal name, date of birth, email, country of residence.
2. Contact verification. Email is verified via one-time link; phone via one-time code.
3. Beneficial ownership. For business accounts, we collect identifying details for any beneficial owner holding 25% or more of the entity.
4. Source-of-funds. For deposits above PKR 1,500,000 in a rolling 30 days, we request source-of-funds documentation.

We reserve the right to request additional documentation at any time and to suspend the account until CDD is complete.

Enhanced Due Diligence is triggered for any customer who:

• Is a Politically Exposed Person (PEP), or a family member / close associate of a PEP.
• Is resident in, or transacting from, a jurisdiction identified by FATF as high-risk or under increased monitoring.
• Has deposited more than PKR 3,000,000 in a rolling 30 days, or more than PKR 7,500,000 in a rolling 12 months.
• Displays a transaction pattern inconsistent with the stated purpose of the account.

EDD adds document-backed proof of address, proof of source of funds, and manual review by our Compliance team before any further activity is permitted.

Every customer is screened against consolidated sanctions lists at onboarding and on an ongoing basis. Lists include, at minimum:

• United Nations Security Council Consolidated List
• US Office of Foreign Assets Control (OFAC) SDN and Consolidated Lists
• EU Consolidated Financial Sanctions List
• UK HM Treasury Consolidated List
• Local sanctions lists of any jurisdiction in which we operate

We do not open accounts for, and will freeze the balances of, any customer resident in a jurisdiction subject to comprehensive sanctions (currently: Iran, North Korea, Syria, Cuba, and the Crimea, Donetsk, Kherson, Luhansk and Zaporizhzhia regions of Ukraine).

All customer activity is monitored on a continuous basis using rule-based and behaviour-based transaction monitoring. Alerts are generated for, among others: rapid velocity of deposits followed by immediate withdrawals, structuring patterns (deposits just under thresholds), unusual geographic activity, and any activity involving a sanctioned or high-risk counterparty.

Alerts are reviewed by our Compliance team within 24 hours and, where appropriate, escalated to the Money Laundering Reporting Officer (MLRO).

Where reasonable grounds exist to suspect money laundering, terrorist financing or predicate financial crime, our MLRO files a Suspicious Activity Report (SAR) with the competent Financial Intelligence Unit in the relevant jurisdiction, without notifying the customer (as required by applicable "tipping-off" prohibitions). We cooperate fully with lawful requests from regulators and law enforcement.

socialmediaboost.it.com will not knowingly serve any customer engaged in any of the following:

• Illegal narcotics, weapons, human trafficking, or child sexual abuse material
• Terrorist financing or funding of prohibited organisations
• Unlicensed money services businesses, shell banks, or Payable-Through Accounts
• Ponzi, pyramid, or other clearly deceptive investment schemes
• Impersonation of public officials or misuse of official emblems / logos
• Any activity subject to a comprehensive OFAC / UN / EU sanctions program

KYC / AML records — including identification documents, transaction records, alerts, investigations and SAR filings — are retained for a minimum of five (5) years after the end of the customer relationship, and longer where required by applicable law.

All socialmediaboost.it.com employees complete AML / CFT / sanctions training within 30 days of joining and annually thereafter. Our MLRO reports directly to senior management. Our program is independently reviewed at least annually and updated to reflect emerging risks and regulatory change.

To report a concern, request records under CDD, or contact compliance directly, please write to compliance@socialmediaboost.it.com. Communications marked as an AML / sanctions concern are reviewed by the compliance team.