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PANDACAPITAL

AML/KYC Policy

Last updated: February 1, 2026

1. Overview

Panda Capital is committed to preventing money laundering, terrorist financing, and other financial crimes. This policy outlines our procedures for customer due diligence, transaction monitoring, and regulatory reporting in compliance with international AML/CFT standards.

2. Know Your Customer (KYC)

All users must complete identity verification before accessing trading services. Verification levels include: (a) Basic: email and phone verification for limited features; (b) Standard: government-issued ID and selfie for full trading access; (c) Enhanced: proof of address and source of funds for high-value accounts.

3. Customer Due Diligence

We perform risk-based due diligence on all customers. This includes verifying identity documents, screening against international sanctions lists (OFAC, EU, UN), checking PEP (Politically Exposed Persons) databases, and assessing the source of funds for high-risk transactions.

4. Transaction Monitoring

Our automated systems monitor all transactions in real-time for suspicious patterns including: unusually large deposits or withdrawals; rapid movement of funds through multiple accounts; transactions inconsistent with a customer's profile; patterns associated with known money laundering typologies.

5. Suspicious Activity Reporting

When suspicious activity is detected, our compliance team conducts an investigation. If warranted, we file Suspicious Activity Reports (SARs) with the appropriate Financial Intelligence Unit (FIU). We are legally prohibited from informing users about filed reports.

6. Record Keeping

We maintain records of all customer identification documents for a minimum of 5 years after account closure. Transaction records are retained for 7 years. Records are stored securely and made available to regulatory authorities upon lawful request.

7. Restricted Jurisdictions

Panda Capital does not provide services to residents of jurisdictions subject to comprehensive sanctions or where cryptocurrency trading is prohibited. We maintain an up-to-date list of restricted jurisdictions and screen all users accordingly.

8. Compliance Team

Our dedicated compliance team, led by our Chief Compliance Officer, oversees all AML/KYC operations. Team members receive regular training on evolving regulations, emerging threats, and best practices in financial crime prevention.