Anti-Money Laundering (AML) & KYC Policy

1. INTRODUCTION

CODEGENIX (trading as ReelMatic) is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) and Know Your Customer (KYC) policy describes how we identify and verify our customers to comply with applicable laws and regulations.

We comply with:

• UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
• EU Anti-Money Laundering Directives (AMLD5)
• Financial Action Task Force (FATF) Recommendations
• Payment Card Industry Data Security Standard (PCI DSS)

2. CUSTOMER DUE DILIGENCE (CDD)

2.1 Standard Verification

For all customers, we collect:

• Full name
• Email address (verified)
• Billing address
• Payment method details (processed securely via our payment processor)

2.2 Enhanced Due Diligence (EDD)

We apply enhanced verification for:

• High-value transactions (above $10,000 USD or equivalent)
• Business/corporate accounts
• Customers from high-risk jurisdictions
• Unusual transaction patterns

Enhanced verification may require:

• Government-issued photo ID (passport, driver's license)
• Proof of address (utility bill, bank statement)
• Source of funds declaration
• Business registration documents (for corporate accounts)

3. TRANSACTION MONITORING

3.1 Automated Monitoring

We use automated fraud detection systems to monitor transactions for:

• Unusual spending patterns
• Rapid succession of high-value purchases
• Transactions from high-risk countries
• Multiple payment methods from one account
• Rapid credit purchases followed by refund requests

3.2 Suspicious Activity Reporting

If we detect suspicious activity, we may:

• Temporarily suspend the transaction pending review
• Request additional information from the customer
• Refuse or reverse the transaction
• Report to the National Crime Agency (NCA) and Financial Intelligence Unit (FIU)

4. RISK ASSESSMENT

4.1 Risk Factors

We assess the following risk factors:

Geographic Risk

• Countries identified by FATF as high-risk or non-cooperative jurisdictions
• Sanctioned countries (OFAC, EU, UN sanctions lists)

Customer Risk

• Politically Exposed Persons (PEPs)
• Customers with complex ownership structures
• Cash-intensive businesses

Transaction Risk

• Unusually large purchases inconsistent with customer profile
• Frequent changes of payment methods
• Transactions with no clear business purpose

5. PROHIBITED ACTIVITIES

We do not permit the use of our services for:

• Money laundering or terrorist financing
• Fraud or financial crime
• Transactions with sanctioned individuals, entities, or countries
• Purchase of credits for the purpose of resale or transfer to third parties
• Structuring transactions to avoid reporting thresholds ("smurfing")

6. DATA RETENTION

In accordance with legal requirements, we retain:

• Customer identification documents: 7 years after account closure
• Transaction records: 7 years from transaction date
• Suspicious activity reports: 7 years from date of report
• Risk assessments: 7 years from completion

7. STAFF TRAINING

All staff members with access to customer information or payment processing receive:

• AML/KYC training upon hiring
• Annual refresher training
• Access to this policy and related procedures
• Clear reporting channels for suspicious activity

8. THIRD-PARTY SERVICE PROVIDERS

We rely on our payment processor for secure payment processing, which implements its own AML/KYC procedures:

• Registered and compliant payment services provider
• Real-time fraud detection systems
• Compliance with international AML standards
• Card verification (CVV, AVS, 3D Secure)

9. YOUR RESPONSIBILITIES

As a customer, you must:

• Provide accurate and truthful information
• Update your information if it changes
• Respond to verification requests promptly
• Not allow others to use your account
• Not use our services for prohibited activities

Failure to comply may result in:

• Account suspension
• Transaction refusal
• Account termination
• Reporting to law enforcement

10. POLICY UPDATES

This policy is reviewed and updated annually or when regulatory requirements change. The current version is always available on our website. Continued use of our services constitutes acceptance of any updates.