Anti-Money Laundering (AML) Policy

1. Introduction

VentNext and its portfolio companies—including HynoGo—are committed to the highest standards of anti-money laundering (AML) compliance. This policy outlines our framework for detecting, preventing, and reporting money laundering, terrorist financing, and other financial crimes.

2. Scope

This policy applies to:

• All VentNext employees, contractors, and directors
• Portfolio companies engaged in financial services, payment processing, or business formation
• Third-party vendors and partners handling financial transactions
• All clients, merchants, and business partners

3. Regulatory Compliance

We comply with applicable AML laws and regulations, including but not limited to the Bank Secrecy Act (BSA), USA PATRIOT Act, Financial Action Task Force (FATF) recommendations, and relevant local jurisdictions where we operate.

4. Customer Due Diligence (CDD)

Before establishing a business relationship, we perform identity verification and risk assessment procedures, including:

• Verification of identity for individuals and beneficial owners
• Confirmation of business registration and legal status
• Assessment of the nature and purpose of the business relationship
• Ongoing monitoring of transactions and account activity
• Enhanced due diligence for high-risk customers and jurisdictions

5. Know Your Customer (KYC)

Our KYC procedures require collection and verification of accurate customer information. We do not accept anonymous accounts or relationships where the identity of the customer or beneficial owner cannot be verified to our satisfaction.

6. Transaction Monitoring

We employ automated and manual monitoring systems to detect unusual or suspicious activity, including large or structured transactions, rapid movement of funds, transactions inconsistent with customer profiles, and activity involving sanctioned individuals or entities.

7. Suspicious Activity Reporting

Employees are required to report suspicious activity to our designated AML Compliance Officer without delay. Where required by law, we file Suspicious Activity Reports (SARs) with the appropriate financial intelligence unit.

8. Sanctions Screening

We screen customers, transactions, and business partners against applicable sanctions lists, including OFAC SDN lists and other international sanctions regimes. We do not engage in business with sanctioned individuals, entities, or countries.

9. Record Keeping

We maintain records of customer identification, due diligence documentation, and transaction data for a minimum period as required by applicable law, typically five to seven years from the end of the business relationship.

10. Training

All relevant personnel receive regular AML training covering regulatory requirements, red flag indicators, reporting procedures, and their individual responsibilities under this policy.

11. Policy Review

This AML Policy is reviewed annually and updated as necessary to reflect changes in regulations, business operations, and emerging risks.