Anti-Money Laundering (AML) Policy

Introduction

VirPoint, operated by Finstar Technologies LTD, is committed to preventing and mitigating the risks of money laundering, terrorist financing, and other illicit financial activities. This AML Policy outlines the measures and procedures implemented to ensure compliance with international standards, including the Financial Action Task Force (FATF) Recommendations, EU AML Directives, and principles derived from ESMA and MiCA frameworks.

Although VirPoint is not a regulated entity, we voluntarily adhere to best practices to provide a safe and transparent trading environment.

• Registered Address: Trust Company Complex, Ajeltake Road, Majuro, MH96960, Marshall Islands

• Operating Address: 100 Bishopsgate, London EC2N 4AG

• Contact: support@virpoint.com

Scope

This policy applies to all users of the virpoint.com platform, as well as employees, contractors, and business partners of VirPoint. It governs all financial transactions and activities performed through our systems, including deposits, withdrawals, and trading operations.

Key Measures

1. Customer Due Diligence (CDD)

• All users must undergo identity verification (KYC) in accordance with VirPoint’s KYC Policy.

• Verification may be required during registration, before withdrawals, or when deposits exceed certain thresholds.

• Enhanced due diligence applies to politically exposed persons (PEPs) and users from higher-risk jurisdictions.

2. Monitoring of Transactions

• All transactions are subject to monitoring using automated systems and manual reviews.

• Activity is assessed for unusual patterns such as rapid deposits and withdrawals, inconsistent trading behaviour, or use of multiple funding sources.

• Suspicious transactions may trigger account restrictions pending review.

3. Suspicious Activity Reporting

• VirPoint maintains procedures to identify and escalate suspicious activities.

• Suspicious Activity Reports (SARs) may be filed with relevant authorities where legally required.

• VirPoint reserves the right to suspend or terminate accounts engaged in activity linked to money laundering or terrorist financing.

4. Record Keeping

• Identification documents, account records, and transaction histories are retained for a minimum of five years after account closure or last transaction.

• All records are stored securely and made available to competent authorities upon request.

5. Cross-Border Transactions

• Transactions involving higher-risk jurisdictions are subject to enhanced due diligence.

• VirPoint applies additional verification checks to address the risks of cross-border transfers, particularly in crypto transactions.

Training and Awareness

All employees and relevant contractors receive regular AML training to ensure awareness of current risks, red flags, and compliance requirements. Training is refreshed periodically to reflect changes in law, regulation, or internal procedures.

Independent Audit and Review

VirPoint periodically reviews and audits its AML framework to ensure continued effectiveness. This includes:

• Reviewing the adequacy of monitoring systems

• Assessing staff training outcomes

• Updating procedures in line with evolving global AML standards

Responsibilities of Users

Users of VirPoint must not engage in, attempt, or facilitate money laundering or terrorist financing activities. By using the platform, you agree to:

• Provide accurate and complete information during registration and verification

• Not conceal or misrepresent the source of your funds

• Cooperate with VirPoint in providing any documents or information requested for compliance purposes

Failure to comply may result in account suspension, restrictions on deposits and withdrawals, or termination of access.

Governing Law

This AML Policy is governed by the laws of the Marshall Islands. Any disputes relating to this policy shall fall under the jurisdiction of the courts of the Marshall Islands.

Updates to This Policy

VirPoint may amend this AML Policy to reflect updates in laws, regulations, or industry standards. Users will be notified of significant changes by email or through platform announcements.

Last Updated: 18 September 2025