In its literal sense, money laundering refers to the process of making illegally-gained proceeds appear legal. Such proceeds can be concealed through monetary transactions or converted into legitimate investments. This Anti-Money Laundering (AML) Policy outlines and specifies the application methods that the Company adheres to under the applicable legislation, primarily Law No. 5549 on the Prevention of Laundering of Proceeds of Crime and Law No. 6415 on the Prevention of the Financing of Terrorism.

Throughout this policy document, the Anti-Money Laundering Policy will be referred to as the AML Policy. The AML Policy includes the rules and practices applicable to users/customers who register on the Site within the scope of the provided services.

The purpose of the Anti-Money Laundering Policy is to inform users/customers that Magician Of Meta Cryptocurrency Trading Platform Inc. assesses, controls, or minimizes the risks related to transactions performed or to be performed by users/customers, raises awareness and informs about efforts to prevent money laundering and terrorist financing, and conducts its activities in compliance with Law No. 5549 on the Prevention of Laundering of Proceeds of Crime and Law No. 6415 on the Prevention of the Financing of Terrorism.

As AreonX, we prioritize utmost care and attention to the security of accounts used by our users/customers. Providing high-quality customer service is one of our core principles. While firmly committed to preventing any activity or operation that could facilitate money laundering, we declare and warn that the AML policy will be applied in its entirety.

AreonX has established and implements its AML Policy in accordance with the applicable legislation and has taken various measures to ensure that all users/customers on the platform verify their identities to a reasonable level, monitor transactions belonging to users/customers as an integral part of risk analysis, report any suspicious transactions conducted by customers to relevant authorities as required by applicable legislation, record transactions, and establish the necessary organizational structure to ensure the implementation and coordination of the AML Policy within the Company.

Within this framework, AreonX has adopted a policy of not engaging in business relationships with criminals or terrorists, not processing transactions originating from criminal or terrorist activities, and not facilitating any transaction related to criminal or terrorist activities. This policy is implemented as a principle across all employees.

Risk Assessment: AreonX protects, monitors, and controls its cryptocurrency trading site against risks through Risk Analysis, Monitoring, and Control activities.

AreonX adopts a risk-based approach to monitor the financial activities of its users/customers, conducting risk analysis with methods determined within the Company to prevent money laundering and terrorist financing. Based on this analysis, it may monitor relevant Users/Customers.

AreonX adopts a risk-based approach to prevent money laundering and terrorist financing in accordance with national and international requirements. Thus, the measures taken against money laundering and terrorist financing are proportional to the identified risks, allowing resources to be allocated efficiently.

The monitoring of user/customer transactions and the analysis of the data obtained are also important tools for risk assessment and detecting suspicious transactions. In cases of suspected money laundering, AreonX reserves the following rights for all transactions:

• Reporting suspicious transactions to MASAK (Financial Crimes Investigation Board)
• Requesting additional documents or information from users based on evaluations
• Suspending or closing the customer account

The above actions do not encompass all potential actions to be taken but serve as criteria in determining whether users/customers are reported in hourly, daily, weekly, and monthly customer tracking under the AML Policy.

AreonX will define its own processes according to the AML Policy, establishing standards to prevent money laundering.

AreonX users/customers complete a verification procedure. AreonX reserves the right to collect identity information of its users/customers for the purposes of the AML policy. This information is processed in accordance with the AreonX Privacy Policy and the Turkish Personal Data Protection Law (KVKK) and is stored securely. AreonX reserves the right to request identity documents from the user/customer, as well as additional documents if there is any suspicion or risk.

In cases where there is suspicion of money laundering or terrorist financing within the scope of the services offered by AreonX, after the necessary investigations are conducted, suspicious transactions will be reported to the Financial Crimes Investigation Board as defined by law, regardless of the transaction amount. Legal, administrative, and criminal actions will be taken against those who actually perform the suspicious transaction, as well as their legal representatives, and any managers or employees who fail to fulfill the obligation to report suspicious transactions.

AreonX has strengthened its monitoring and control measures by establishing a dedicated Anti-Money Laundering Department. The Anti-Money Laundering Department is responsible for collecting identity information of users/customers, creating reports with reference to the applicable laws and regulations, presenting them to management, preparing them for official institutions if requested, monitoring unusual transaction patterns of customers, and similar tasks.

AreonX strives to fulfill its obligations to the best degree within the framework of all outlined matters. Accordingly, following its stringent policy on preventing money laundering, it provides training to its employees and ensures that all informational and training documents are kept up to date.