Anti-Money Laundering (“AML”) and Counter-Terrorist Financing (“CTF”) Policy

Last updated: 03 March 2026

1. Purpose and Scope

Money laundering refers to activities intended to conceal or disguise the origin of proceeds derived from criminal activity so that such proceeds appear to originate from legitimate sources. Terrorist financing involves the collection or provision of funds or assets for the purpose of supporting terrorist acts or organizations.

Koson PRO Corporation (“Koson”) recognizes the importance of supporting global efforts to combat money laundering, terrorist financing, and related financial crime risks.

This AML and CTF Policy describes the high-level principles applied by Koson in connection with the operation of its website and technology platform and explains how Koson supports AML and CTF compliance in cooperation with licensed financial institutions and regulated service providers.

2. Regulatory Status

Koson is incorporated under the laws of the Republic of Panama and operates as a technology software solutions provider and website operator.

Koson is not a bank, payment service provider, electronic money institution, card issuer, custodian, money transmitter, or other regulated financial institution.

Koson does not:

perform regulated customer due diligence (CDD);
conduct know-your-customer (KYC) procedures as a licensed financial entity;
conduct regulated transaction monitoring;
file suspicious transaction reports;
act as a reporting entity under AML or CTF legislation.
All regulated AML, CTF, sanctions screening, customer identification, and transaction monitoring activities are performed exclusively by duly licensed Regulated Providers operating under their own legal and regulatory obligations.

3. Cooperation with Regulated Providers

Financial services made available through the platform are performed exclusively by licensed Regulated Providers.

Such Regulated Providers may include independent third-party institutions as well as affiliated entities holding regulatory registrations in relevant jurisdictions.

Koson supports AML and CTF compliance by:

facilitating the secure transmission of information required by Regulated Providers;
applying technical and operational access controls;
cooperating with licensed partners in connection with lawful compliance requests;
implementing internal safeguards designed to reduce misuse of the platform.

Koson does not exercise regulatory discretion over Users or Transactions.

4. Risk-Based Approach

A risk-based approach to AML and CTF is applied by Regulated Providers in accordance with their regulatory obligations.

applying access restrictions and service limitations based on geographic and sanctions-related risk factors;
restricting access from jurisdictions subject to applicable sanctions or heightened regulatory risk;
maintaining internal controls designed to mitigate misuse of the platform within the scope of Koson’s role.

All customer risk classification, enhanced due diligence, ongoing monitoring, and regulatory risk decisions are carried out solely by Regulated Providers.

5. Customer Due Diligence

Koson does not conduct customer due diligence or beneficial ownership verification as a regulated entity.

All identity verification, KYC, enhanced due diligence, politically exposed person (PEP) screening, and ongoing customer review processes are performed exclusively by licensed Regulated Providers or specialized verification providers engaged by them.

Koson’s role is limited to:

facilitating secure collection and transmission of required information;
providing technical integration support;
displaying status updates made available by Regulated Providers.

6. Transaction Monitoring and Reporting

Koson does not perform regulated transaction monitoring or suspicious activity reporting.

All transaction monitoring, detection of suspicious activity, and reporting to competent authorities are carried out solely by licensed Regulated Providers.

Koson may support such processes by:

maintaining internal technical monitoring tools designed to detect misuse of the platform
cooperating with licensed providers in connection with lawful investigations;
implementing technical restrictions where reasonably necessary to prevent abuse.

7. Sanctions Compliance

Koson supports compliance with applicable international sanctions regimes.

Koson does not conduct regulated sanctions screening as a financial institution.

All sanctions screening, name screening, and transaction-level sanctions controls are performed exclusively by licensed Regulated Providers in accordance with their regulatory obligations.

Koson may implement access restrictions or service limitations in order to comply with the legal, regulatory, and contractual requirements of Regulated Providers.

8. Record Retention

Koson maintains operational and technical records relating to the use of the platform in accordance with applicable laws and internal policies.

Records required for AML, CTF, customer due diligence, transaction monitoring, or regulatory reporting purposes are maintained exclusively by licensed Regulated Providers.

9. Training and Internal Awareness

Koson maintains internal compliance awareness appropriate to its role as a non-regulated technology service provider.

Such awareness focuses on:

recognizing potential misuse of the platform;
understanding high-level AML and sanctions risks;
ensuring effective cooperation with licensed Regulated Providers.

Koson does not provide regulated AML training applicable to licensed financial institutions.