Effective Date: 21st June 2021 (Rev. 09/29/2025)

Welcome to Sigtrade LLC, a cryptocurrency trading platform that offers investment opportunities in digital currencies, commodities, and bonds. These Terms and Conditions ("Terms") apply to your use of our website and services, and by accessing or using Sigtrade LLC, you agree to comply with and be bound by these Terms.

If you do not agree to these Terms, please do not use our website or services.

1. Purpose of AML Policy

The purpose of this Anti-Money Laundering (AML) Policy is to establish procedures that help Sigtrade LLC prevent, detect, and report any activity related to money laundering or terrorist financing. The policy is designed to comply with international and local anti-money laundering regulations and to protect the integrity of the platform.

2. Compliance with Legal and Regulatory Requirements

Sigtrade LLC is committed to complying with all applicable AML laws and regulations. We adhere to both local and international standards to detect, prevent, and report any suspicious activity. Our platform is subject to the relevant laws in Estonia & USA, as well as any other jurisdiction we operate in.

3. Know Your Customer (KYC) Requirements

As part of our AML procedures, Sigtrade LLC implements a "Know Your Customer" (KYC) policy. All users are required to provide verifiable personal information before engaging in any financial transactions on the platform. This includes but is not limited to:

• Full legal name

• Date of birth

• Residential address

• Valid government-issued identification (e.g., passport, national ID, driver’s license)

• Proof of address (e.g., utility bill, bank statement)

We may also request additional documentation to verify the source of funds or wealth if deemed necessary.

4. Suspicious Activity Monitoring

Sigtrade LLC employs sophisticated monitoring systems designed to detect suspicious transactions and unusual behavior. This includes, but is not limited to:

• Large, irregular, or rapid transactions

• Transactions involving high-risk countries or jurisdictions

• Multiple failed KYC attempts

• Patterns of behavior suggesting layering or structuring to avoid detection

If we detect any suspicious activity, we will review the transaction in detail and, where appropriate, report it to relevant authorities.

5. Transaction Reporting and Recordkeeping

Sigtrade LLC

will maintain a record of all transactions conducted on the platform. These records will be securely stored for a minimum period in accordance with regulatory requirements, ensuring full compliance with AML laws.

If a suspicious transaction is identified, we may file a Suspicious Activity Report (SAR) or a similar report with the relevant authorities in the appropriate jurisdiction(s). We may also suspend or freeze accounts involved in suspicious activity during an investigation.

6. Customer Due Diligence (CDD)

Sigtrade LLC follows Customer Due Diligence (CDD) procedures to assess and mitigate the risk of illegal activities on our platform. This includes:

• Verifying the identity of customers through KYC checks

• Monitoring the source of funds and wealth

• Risk-assessing customers based on factors such as location, occupation, transaction history, and behavior

• Enhanced due diligence (EDD) for higher-risk customers, including Politically Exposed Persons (PEPs) and individuals from high-risk jurisdictions

7. Risk Assessment

Sigtrade LLC evaluates the risk of money laundering and terrorist financing associated with different types of customers, transactions, and services. This risk assessment is an ongoing process and is updated regularly to reflect changes in laws, regulations, and business operations.

We categorize customers and transactions based on the perceived risk level and apply appropriate controls, including enhanced due diligence for high-risk categories.

8. Staff Training and Awareness

Sigtrade LLC ensures that all employees, particularly those in customer service, compliance, and risk management roles, are properly trained in AML and KYC procedures. Our training program includes:

• Regular updates on AML regulations and trends

• Recognition of red flags for suspicious activity

• Reporting procedures for suspected money laundering or terrorist financing

• Security and privacy best practices for handling customer data

We require all staff to actively comply with our AML policy and report any suspicious activities immediately.

9. Cooperation with Authorities

Sigtrade LLC cooperates fully with regulatory and law enforcement authorities, providing all necessary information to assist in investigations into money laundering, terrorist financing, or other criminal activities. We will comply with valid legal requests for information and maintain transparent records of any actions taken under this policy.

10. Account Suspensions and Terminations

Sigtrade LLC reserves the right to suspend or terminate any account if there is a reasonable belief that the account has been used for money laundering, terrorist financing, or any other illegal activities. Suspended or terminated accounts may be reported to the relevant authorities in accordance with applicable laws.

11. Data Protection and Privacy

We take your privacy and security seriously. Sigtrade LLC ensures that all personal data collected during the KYC and AML process is securely stored and handled in accordance with our Privacy Policy. We do not share customer information with third parties unless required by law or regulatory authorities.

12. Updates to This AML Policy

Sigtrade LLC, reserves the right to amend or update this AML Policy at any time. Any changes will be effective immediately upon posting on our platform. We recommend you review this policy periodically to stay informed about our AML practices.

13. Contact Information

If you have any questions regarding this Anti-Money Laundering (AML) Policy or need further assistance, please contact our compliance team at support@sigtrade.net.

End of AML Policy