ANTI MONEY LAUNDERING & KYC POLICY

August 2025

Section 1: Background and Introduction

On October 26, 2001, the USA PATRIOT Act (the "Act") became law (amending certain provisions of the Bank Secrecy Act of 1970). Section 352 of the Act requires every "financial institution" to establish an anti-money laundering (AML) program, which includes at a minimum:

•The development of internal policies, procedures, and controls

•The designation of a compliance officer

•An ongoing employee training program

•An independent audit function to test the program

Section 2: Scratchee.com Policy

Scratchee.com is committed to full compliance with all applicable laws and regulations regarding Money Laundering & Terrorist Financing. Scratchee.com consider Integrity as a key commitment on the part of the firm to uphold strict standards of ethical conduct and hence preservation of a stable value for society confidence. These policies endorse the strict compliance with the legal framework governing the prevention of money laundering and terrorism financing.

Section 3: Key Definitions

3.1. Money Laundering

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds in a way to make those proceeds appear to have been derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages.

3.2. Placement

Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler's checks, or deposited into accounts at financial institutions.

3.3. Layering

At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin.

3.4. Integration

At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate business.

Section 4: Customer Due Diligence Procedures

Scratchee.com has an established Customer Due Diligence Procedures (CDD) which requires customer to provide following information at minimum:

-Customer Full Name

- Date of Birth

-Full Address with Zip Code

-Telephone Number

-Email address

Section 5: Sanctions Screening

Scratchee.com will screen customer name against OFAC list to ensure customer is not in SDN list. If there is an indication of a possible match, transaction will put on hold and reviewed by the MLCO and will only be processed, if approved by MLCO.

Section 6: Enhanced Due Diligence Procedures

6.1 High-Risk Clients

Scratchee.com will take enhanced measures for identifying customers, keeping records, and monitoring financial transactions in respect of the activities that pose the high risk. Scratchee.com must periodically conduct ongoing monitoring of the business relationship with its customers based on risk. The level of monitoring which is conducted varies depending on the customer’s risk assessment results.

Based on risk assessment, if there is a need for any additional information about the user or the transaction purpose, Scratchee.com may perform enhanced due diligence which include:

● Obtaining additional information on a client i.e. public database and the internet); and,

● Obtaining information on the client's source of funds or source of wealth

6.2 Politically Exposed (PEP)

Politically Exposed Persons (PEP) is defined as “a person entrusted with a prominent position that typically comes with the opportunity to influence decisions and the ability to control resources. The influence and control a PEP have, puts them in a position to impact policy decisions, institutions, and rules of procedure in the allocation of resources and finances, which can make them vulnerable to corruption.”

As part of KYC Process, Scratchee.com is required to make the PEP determination when entering a business relationship with customers whether a person is a foreign PEP, a domestic PEP, a Head of International Organization (HIO), or a family member or close associate of one of these people. Also required to conduct periodic monitoring of business relationships and determine when a fact is detected about an existing business relationship and determine if they become a PEP or HIO, or a close associate.

Scratchee.com will ensure the required PEPs are identified, and that CEO/CCO approval is obtained for establishing a business relationship with a PEP.

Section 7: Roles and Responsibilities

5.1. Money Laundering Compliance Officer (MLCO) Designation and Duties

Scratchee.com has designated Anti-Money Laundering Program Compliance Officer with full responsibility for the company’s AML program. The duties of the AML Compliance Officer will include monitoring the company’s compliance with AML obligations, overseeing communication, and training for Management, and employees in the areas of AML/BSA and OFAC compliance. The AML Compliance Officer will also ensure firm keeps and maintains all required AML records and will ensure Suspicious Activity Reports (SARs) are filed with the Financial Crimes Enforcement Network (FinCEN) when appropriate. Responsibilities of the MLCO include the following:

- Coordination and monitoring of Scratchee.com day-to-day compliance with applicable Anti- Money Laundering Laws and Regulations and firm internal Anti-Money Laundering Policy and Procedures.

- Conduct staff training programs for appropriate personnel related to the Scratchee.com .’s anti-money laundering policy and procedures and maintaining records evidencing such trainings.

- Receive and review any reports of suspicious activity from staff.

- Sanction Screening of customer names before processing order to ensure compliance with OFAC and other applicable Sanctions lists

- Coordination of enhanced due diligence procedures regarding clients and respond to both internal and external inquiries regarding Scratchee.com AML/CFT policies and procedures.

- Notify the Authority of any suspicious money laundering or financing of terrorism activity

5.2. Employees

It is the policy of the firm that every member of staff shall pay attention to and report to the MLCO if any transactions made on behalf of a person whose identity has not been established or suspicious transaction.

Section 8: Monitoring Accounts for Suspicious Activity

Scratchee.com MLCO will monitor account activity for unusual size, volume, pattern or type of transactions, accounting for risk factors and red flags which are appropriate to our business.

Section 9: Suspicious Transaction Reporting (SAR) and BSA Reporting

Scratchee.com will file a SAR with FinCEN for any transactions conducted or attempted by, at or through firm where we know, suspect, or have reason to suspect:

- The transaction involves funds derived from illegal activity or is intended or conducted to hide or disguise funds or assets derived from illegal activity as part of a plan to violate or evade federal law or regulation or to avoid any transaction reporting requirement under federal law or regulation.

- The transaction is designed, whether through structuring or otherwise, to evade any requirements of the BSA regulations.

- The transaction has no business or apparent lawful purpose or is not the sort in which the customer would normally be expected to engage, and after examining the background, the possible purpose of the transaction and other facts, we know of no reasonable explanation for the transaction; or

- The transaction involves the use of the firm to facilitate criminal activity.

- Scratchee.com . will retain copies of any SAR filed and the original or business record equivalent of any supporting documentation for five years from the date of filing the SAR. We will identify and maintain supporting documentation and make such information available to FinCEN, as well as any other appropriate law enforcement agencies, federal or state regulators upon request.

- Scratchee.com will not notify any person involved in the transaction, which is being reported except as permitted by BSA regulations.

Section 10: AML Recordkeeping

It is the policy of firm to follow its Records Retention Policy. This policy complies with existing BSA and other recordkeeping requirements.

Section 11: Training Programs

Company-Wide Training – All employees are required to participate in a yearly training program which currently has following components at minimum:

•Ethics

•Compliance Essentials

•Anti-Money Laundering

•Economic Sanctions

Section 12: Independent Review of Compliance Program

Scratchee.com to undertake an independent review of the compliance regime to test its effectiveness related to compliance with AML & KYC Policy. This independent effectiveness review shall include interviews, sampling, and testing of “KYC” processes, transaction monitoring and reporting, and their supervisors, to determine their knowledge of the legislative requirements and Scratchee.com policies and procedures.

Section 13: Periodic Review

This policy to be reviewed on an annual basis.