Anti-Money Laundering (AML) Policy

1. Purpose

Treeova Technologies ("Treeova," "we," "us") is committed to helping prevent money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering ("AML") Policy describes the controls we use to detect, deter, and respond to suspicious activity, and the standards we expect from users of our platform.

2. Scope

This policy applies to:

• Treeova's website, products, and platform features
• Treeova personnel, contractors, and service providers acting on Treeova's behalf
• Users and partners to the extent they interact with Treeova's platform

Important clarification: Treeova is a software-as-a-service ("SaaS") provider. We do not act as a broker-dealer, custodian, bank, money services business, payment processor, or financial institution. We do not hold, receive, transmit, or custody customer funds or securities. Trading activity is placed and executed through third-party brokers and/or other regulated counterparties selected and controlled by the user.

3. Definitions (plain-language)

• Money laundering: Hiding the source of illegally obtained funds.
• Terrorist financing: Providing funds or support for terrorist activities.
• Sanctions: Restrictions imposed by governments (e.g., U.S. OFAC) on certain individuals, entities, and jurisdictions.
• Suspicious activity: Behavior that may indicate illegal activity, including attempted misuse of the platform.

4. Our Risk-Based Approach (Overview)

Treeova maintains a risk-based program intended to help:

• Identify and assess financial crime risks relevant to our SaaS business model
• Implement reasonable controls to mitigate those risks
• Review and escalate concerns promptly
• Comply with applicable laws and contractual obligations

5. User Eligibility and Geographic Restrictions

Treeova may restrict or deny access to the platform for users who:

• Are located in jurisdictions subject to comprehensive sanctions
• Appear on sanctions lists or other watchlists
• Are associated with prohibited or high-risk activity

6. Account Information and Verification

To reduce fraud and platform misuse, Treeova may collect and verify certain account information. Depending on the situation, this may include:

• Name, email address, phone number, and other account information
• Country/region of residence
• Government-issued identification (directly or via a third-party verification provider)
• Supporting documentation reasonably requested to validate identity or account control

If a user does not provide required information, we may limit, suspend, or terminate access to the platform.

7. Sanctions and Watchlist Screening

Treeova may screen users and certain counterparties against relevant sanctions and watchlists, including those maintained by the U.S. Office of Foreign Assets Control ("OFAC") and other authorities.

8. Prohibited Use

Users may not use Treeova's platform to:

• Launder money or conceal the proceeds of crime
• Finance terrorism or support sanctioned entities
• Evade sanctions or regulatory requirements
• Engage in fraud, market manipulation, or other unlawful conduct
• Misrepresent identity or provide false information

9. Monitoring and Detection (Platform-Level)

Treeova uses a combination of automated and manual controls to identify potentially suspicious activity related to platform access and misuse. Depending on the data available to Treeova, monitoring may include:

• Account and login behavior (e.g., unusual access patterns)
• Identity inconsistencies or repeated verification failures
• Indicators of fraud, account takeover, or attempted misuse
• Reports from users, partners, or third parties

Note: Treeova's visibility into order routing, execution, and brokerage account funding is limited because trading is conducted through third-party brokers and platforms. Those brokers and platforms may maintain their own AML programs and monitoring.

10. Investigation and Response

When we identify or receive a report of potentially suspicious activity, we may:

• Request additional information or documentation
• Restrict certain features (e.g., strategy sharing, prompt sharing, or integrations)
• Suspend or terminate accounts
• Notify relevant third parties (such as a connected broker or integration partner) where appropriate
• Report matters to law enforcement or regulators when required

Treeova does not disclose whether any report has been made, except as permitted by law.

11. Recordkeeping

Treeova maintains records related to this policy and related reviews for the period required by applicable law and our internal retention standards.

12. Training and Accountability

Treeova provides AML and fraud-awareness training to relevant personnel and maintains internal procedures for:

• Identifying red flags
• Escalating concerns
• Documenting outcomes

An internal compliance owner (or designated responsible person) oversees periodic reviews of this policy.

13. Third-Party Service Providers

Treeova may use third-party vendors to support identity verification, fraud prevention, sanctions screening, hosting, and other operational needs. We assess vendors based on risk and require appropriate safeguards.

14. Privacy

We handle personal information in accordance with our Privacy Policy. Information may be collected, used, and shared as necessary to verify identity, prevent fraud, protect the platform, and comply with legal obligations.

15. Changes to This Policy

We may update this AML Policy from time to time. Updates will be posted on our website with a revised "Last updated" date.

16. Contact

Questions about this AML Policy may be directed to:

• Treeova Technologies
• Email: support@treeova.com