AML Policy

Last Update: December 12, 2025

Dream Finance U.S. (“Dream Finance” or the “Company”) has no tolerance for money laundering, the financing of terrorism or any other form of illicit activity, and is committed to implementing policies, procedures and controls shaped by the best industry practices and the most effective anti-money laundering standards applied in the United States and worldwide. These rules apply to, without exception, all employees of the Company, its Board members, officers, contractors, and consultants.

The purpose of this document is to provide the Company’s partners, clients, vendors, contractors, employees, regulators, law enforcement and other concerned stakeholders with a high-level overview of the Company’s AML/CFT compliance regime elements and procedures. By no means shall this document be read as an entire set of all policies, procedures and controls in place implemented by the Company for prevention of money laundering, financing of terrorism and other forms of illicit activity.

This document and all underlying policies, processes and procedures are prepared in line with provisions, requirements and recommendations of:

• the Bank Secrecy Act (BSA) and its implementing regulations, as amended from time to time;
• the USA PATRIOT Act, as amended from time to time;
• guidance, rules and recommendations issued by the Financial Crimes Enforcement Network (FinCEN), the U.S. Department of the Treasury, and other competent U.S. supervisory authorities;
• FATF Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers (VASPs).

The Company operates from, and under the laws and regulatory requirements of, the United States. The United States was among the first jurisdictions in the world to introduce comprehensive Anti-Money Laundering (“AML”) and Countering the Financing of Terrorism (“CFT”) obligations for businesses engaged in activities involving virtual assets. As a result, each entity rendering such services from or within the United States must register with the Financial Crimes Enforcement Network (FinCEN) as a Money Services Business (MSB) and comply with all applicable BSA/AML requirements.

Dream Finance U.S. is registered with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) as a Money Services Business (MSB) authorized to provide virtual currency exchange and virtual currency transmission services in accordance with applicable U.S. federal laws and regulations.
MSB registration information can be verified through the official FinCEN MSB Registrant Search.

As a regulated business, the Company is required to comply with the Bank Secrecy Act (BSA), its implementing regulations, and applicable Office of Foreign Assets Control (OFAC) sanctions requirements. These obligations require the Company to identify and verify its customers, conduct ongoing monitoring of customer activity (including transaction monitoring), maintain records and documents for the legally prescribed retention period, and report certain activities or suspicions to the competent authorities, including filing required reports with FinCEN.

The Company understands money laundering in accordance with applicable U.S. legislation as including, inter alia:

1. the conversion or transfer of property, knowing that such property is derived from criminal activity, for the purpose of concealing or disguising its illicit origin or assisting any person involved in such activity to evade legal consequences;
2. the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity;
3. the acquisition, possession, or use of property, knowing, at the time of receipt, that such property was derived from criminal activity;
4. participation in, attempts to commit, aiding, abetting, or facilitating any of the acts referred to above.

Terrorist financing provides funds or other assets for terrorist activity. From a legal standpoint, it means the provision or collection of funds, by any means, directly or indirectly, with the intention that they be used, or in the knowledge that they are to be used, in full or in part, to carry out terrorist acts as defined under applicable U.S. federal law, including the Bank Secrecy Act (BSA), the USA PATRIOT Act, and relevant U.S. counter-terrorism statutes. Terrorist activity is generally aimed at intimidating a population or compelling a government or international organisation to act or refrain from acting. This may be done by intentionally killing or seriously harming people, endangering life, causing substantial property damage likely to seriously harm people, or seriously interfering with or disrupting essential services, facilities or systems.

Risk-Based Approach and Risk Assessment

The Company applies a risk-based approach to all prospective clients. The Company collects and evaluates information and documentation necessary to assess the money laundering, terrorist financing, and sanctions risks associated with each customer. Employees of the Company exercise due care and professional judgment when assessing the customer’s risk profile, taking into account factors such as customer type, geographical exposure, products and services used, delivery channels, and transactional behavior. The Company conducts its business in accordance with the highest ethical and regulatory standards and will not enter into business relationships with individuals or entities whose activities may pose unacceptable legal, reputational, regulatory, or sanctions-related risks, or otherwise fall outside the Company’s risk appetite.

For the purpose of identifying, assessing, and analyzing the risks of money laundering, terrorist financing, and sanctions exposure related to its activities, the Company performs a Customer Risk Assessment. This assessment takes into account the following categories:

• Customer Risk;
• Geographical Risk;
• Product Risk;
• Delivery Channel;
• Behavioral or Transactional Risk.

Each customer is assigned a risk level based on these factors. The assigned risk level is reviewed periodically and updated where necessary, taking into consideration changes in the customer’s profile, behaviour, business activity, or any other information obtained during ongoing due diligence and transaction monitoring, in accordance with applicable U.S. federal requirements, including those established under the Bank Secrecy Act (BSA), FinCEN regulations, and relevant guidance.

Money Laundering Reporting Officer

The management of the Company appoints a Money Laundering Reporting Officer (MLRO), who acts as the Company’s designated Compliance Officer for purposes of the Bank Secrecy Act (BSA) and related U.S. anti-money laundering requirements, and is responsible for the implementation and oversight of the Company’s AML/CFT program. The MLRO reports directly to senior management and has the authority, resources and unrestricted access to all information necessary to perform these duties across all business units of the Company.

Only a person who has the education, professional suitability, abilities, personal qualities, experience and impeccable reputation required for the performance of these duties may be appointed as the MLRO. The appointment of the MLRO is carried out in accordance with applicable U.S. regulatory expectations, including those issued by FinCEN.

The duties of the MLRO include, inter alia:

• organising the collection and analysis of information related to unusual transactions or transactions or circumstances suspected of money laundering, terrorist financing or sanctions violations that become apparent in the activities of the Company;
• reporting to the Financial Crimes Enforcement Network (FinCEN) without delay by filing Suspicious Activity Reports (SARs) in the event of suspicion of money laundering or terrorist financing;
• submitting periodic written reports to senior management of the Company regarding compliance with the requirements arising from applicable U.S. legislation and regulatory guidance;
• performing any other duties and obligations related to ensuring compliance with Anti-Money Laundering and Countering the Financing of Terrorism requirements applicable to the Company under U.S. law.

Rules of Procedure and Internal Control Rules

The Company has developed and implemented internal rules of procedure that enable the effective mitigation and management of money laundering, terrorist financing, and sanctions risks identified through its risk-based approach. All employees of the Company are required to comply with these rules of procedure.

The internal rules of procedure include, inter alia:

• the application of customer due diligence measures, including enhanced due diligence where appropriate;
• the identification and assessment of customer-related risks and the determination of the customer’s risk profile;
• the methodology and internal instructions to be followed when the Company identifies unusual activity or suspects money laundering or terrorist financing, including procedures for fulfilling reporting obligations to the competent authorities, including the Financial Crimes Enforcement Network (FinCEN);
• the procedures for data retention and ensuring the availability of records in accordance with applicable legal requirements under the Bank Secrecy Act (BSA);
• instructions for identifying politically exposed persons and persons subject to U.S. sanctions administered by the Office of Foreign Assets Control (OFAC).

The Company applies the following customer due diligence measures:

• identifying the customer and verifying the information provided using reliable and independent sources, including electronic identification tools and trusted electronic verification services;
• identifying the beneficial owner and taking appropriate steps to verify their identity and to understand the customer’s ownership and control structure in accordance with the Customer Due Diligence Rule (CDD Rule);
• understanding the nature and purpose of the business relationship and, where relevant, obtaining additional information to support this assessment;
• determining whether a customer or related person is a politically exposed person (PEP), a family member of a PEP or a close associate of a PEP;
• conducting ongoing monitoring of the business relationship to ensure that transactions and customer activity are consistent with the Company’s knowledge of the customer and their risk profile, and filing Suspicious Activity Reports (SARs) with FinCEN where required.

Enhanced Due Diligence (EDD)

The Company applies enhanced due diligence measures in situations where the risk of money laundering or terrorist financing is higher than usual, or where additional verification is required to ensure that the risks associated with a customer can be effectively managed and mitigated.
EDD measures are applied in particular when:

• during identification or verification, doubts arise regarding the accuracy of the information provided, the authenticity of documents, or the identification of the beneficial owner;
• the customer, beneficial owner or a related person is identified as a politically exposed person (PEP) or a close associate or family member of a PEP, in accordance with applicable U.S. regulatory guidance;
• the customer is associated with, or originates from, a jurisdiction identified by the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN), or the Office of Foreign Assets Control (OFAC) as presenting elevated money laundering, terrorist financing, or sanctions risks.

The Company applies EDD whenever its risk assessment determines that the nature of the customer’s business, activity, behaviour or other relevant factors present a higher-than-usual risk of money laundering or terrorist financing.

PEP Definition and Screening

The Company applies enhanced due diligence measures to politically exposed persons (PEPs), their family members, and close associates in accordance with international standards and applicable U.S. legislation, such as the Bank Secrecy Act (BSA) and USA PATRIOT Act. PEPs may present a higher risk of money laundering or corruption due to the influence and authority associated with their public roles.

A PEP is defined as a natural person who is, or has been, entrusted with prominent public functions, including:

• Head of state or head of government;
• Minister, deputy minister, or assistant minister;
• Member of congress or a similar legislative body;
• Senior official of a political party;
• Member of the judiciary, such as a supreme court judge;
• Member of the board of a central bank or regulatory body;
• Ambassador, chargé d’affaires, or high-ranking military officer;
• Senior executive of a state-owned enterprise;
• Director, deputy director, or member of the management or supervisory body of an international organisation.

Family members of a PEP include:

• The spouse or person considered equivalent to a spouse;
• The children of a PEP and their spouses or persons considered equivalent to spouses;
• The parents of a PEP.

Close associates of a PEP are individuals who:

• Are known to have joint beneficial ownership of legal entities or arrangements with a PEP, or have other close business relationships with a PEP;
• Have sole beneficial ownership of a legal entity or arrangement that is known to have been established for the benefit of a PEP.

The Company screens customers, beneficial owners, and related persons against PEP databases as part of its due diligence measures and applies enhanced monitoring where necessary, in line with applicable U.S. AML/CTF regulations.

Sanctions Screening

The Company recognises that dealing with persons or entities subject to international sanctions presents significant legal and regulatory risks. The Company therefore conducts sanctions screening as part of its customer due diligence and ongoing monitoring processes.

The Company screens customers, beneficial owners and relevant associated persons against applicable sanctions lists, including at minimum:

• sanctions administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC);
• United Nations (UN) sanctions;
• sanctions issued by the U.S. Department of State where applicable;
• sanctions issued under relevant U.S. federal laws and executive orders;
• other international sanctions regimes as required by the Company’s policies or contractual obligations.

Any confirmed match (“true hit”) is immediately escalated to the Company’s designated AML Officer for assessment and further action in accordance with applicable legal obligations. The Company does not establish or continue business relationships where sanctions risks cannot be effectively mitigated.

Suspicious Activity Monitoring and Reporting

If the Company identifies activity or circumstances that may indicate the use of criminal proceeds, terrorist financing, or any other criminal offence or attempt thereof, or if the Company knows or suspects that a transaction or activity may constitute money laundering or terrorist financing, the MLRO must report such activity to the Financial Crimes Enforcement Network (FinCEN) without delay and in accordance with the reporting timelines set out under the Bank Secrecy Act (BSA), including the requirement to file a Suspicious Activity Report (SAR) no later than 30 calendar days from the date the suspicion is first detected.

The Company and all its employees, officers and directors are strictly prohibited from informing the customer, their beneficial owner, representative or any third party about a report submitted to FinCEN, the intention to submit such a report, or the existence of an investigation or criminal proceedings. This prohibition on “tipping off” is mandatory under applicable U.S. federal law.

Data Retention

The Company retains customer identification data, verification records, transaction information and other documents required under applicable U.S. AML/CTF legislation — including the Bank Secrecy Act (BSA), USA PATRIOT Act, and Financial Crimes Enforcement Network (FinCEN) regulations — for the legally prescribed retention period, which is generally five years from the end of the business relationship or completion of the relevant transaction.

The Company implements appropriate measures to ensure the protection and confidentiality of personal data in accordance with applicable U.S. federal and state privacy laws. Personal data obtained for the purposes of customer due diligence and ongoing monitoring is processed solely for the prevention of money laundering, terrorist financing, and other financial crimes, and is not used for any unrelated purposes, including marketing.

Training

The MLRO ensures that all employees of the Company are aware of their legal obligations in the area of anti-money laundering, counter-terrorist financing and sanctions compliance by implementing a comprehensive training programme in accordance with the Bank Secrecy Act (BSA), the USA PATRIOT Act, regulations issued by the Financial Crimes Enforcement Network (FinCEN), and other applicable U.S. federal requirements.

The content and frequency of training are determined based on the Company’s risk profile, regulatory developments, employees’ responsibilities and changes in the business model. Training is provided upon hiring and on a regular basis thereafter, and it may be supplemented whenever necessary to reflect updates in legislation, emerging risks or new typologies issued by FinCEN, federal regulators, or law enforcement.

The training programme is designed to ensure that employees understand the applicable legal requirements, the risks associated with money laundering and terrorist financing, the Company’s internal systems and controls, and the procedures for identifying and reporting suspicious activity, including the requirements for filing Suspicious Activity Reports (SARs) with FinCEN.

Cooperation and Exchange of Information

The Company cooperates with supervisory authorities and law enforcement agencies in the prevention and detection of money laundering, terrorist financing and sanctions violations. The Company provides information and responds to requests from competent authorities in a timely manner and in accordance with applicable legal obligations, including data protection and confidentiality requirements.

For official requests for information, please contact: [email protected]

If the requesting authority is located outside the United States, the provision of information may be subject to international cooperation procedures such as the Mutual Legal Assistance Treaty (MLAT) or other applicable legal frameworks.