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AML & KYC Policy

1. This Anti–Money Laundering and Know Your Customer Policy (hereinafter the “Policy”) sets out the general rules and procedures followed by OmegaPro LTD on the implementation of the Know – Your Customer (hereinafter “KYC”) procedures in accordance with the relevant Anti – Money Laundering laws, rules and regulations (hereinafter “AML”).

2. This Policy is part of the OmegaPro LTD commitment in participating in international efforts to counter money laundering and terrorism financing.

3. This Policy applies uniformly to any User that wishes to use the services offered by or otherwise benefit from the use of the website of OmegaPro LTD. Therefore, each User that visits the OmegaPro LTD website must carefully read and comply with this Policy. If any User does not agree with this Policy or any part of it, then such User must refrain from accessing and using the website and/or the services offered by the website.

4. OmegaPro LTD reserves the right to modify or amend this Policy at its sole discretion. Any revisions to this AML/KYC Policy will be posted on our website. If we make changes, we will notify you by revising the date at the top of this Policy. We strongly recommend you to periodically visit the website to review any changes that may be made to this Policy to stay updated on our AML/KYC practices. Your continued usage of the website and/or services shall mean your acceptance of those amendments.

5. This Policy is a part of and is to be read along with our Terms of Use and Privacy Policy. You may view the current version of these policies on our website.

6. The terms “We”, “Our”, “Company” and “Us” refer to OmegaPro LTD. The term “User”, “You” and “Your” refer to a user of our website.

Due Diligence and Know Your Customer Procedures

1. You may either at the time of registering as a User or upon execution of any visa card payment transactions and/or any other form of transaction available through our website and generally when using the services offered by our website or periodically for purposes of updating records and on-going due-diligence procedures under AML laws and regulations, be required to take part in the User identification and verification process. For this purpose, we will follow the procedure prescribed under this Policy.

2. As part of our User identification and verification process we may collect the following information but OmegaPro LTD, reserves the right to request any additional information: • Individual Users: name, date of birth, email address, phone number and residential address, copies or certified copy of passport/identity card, documents pertaining to business/financial status of such User; • Business Users: business name, name, contact-details, and copy of passport/identity card of the authorized representative, one certified copy each of the certificate of incorporation, memorandum and articles of association/partnership deed (as the case may be), board resolution and/or other authorization documents giving authority to the representative chosen to execute transactions on the website. • Additional Information from Business Users: If the User is a legal entity, the Beneficial Owner of such entity must be identified and you must also assist in the verification of the identity of such Beneficial Owner and any individual who purports to act on behalf of such legal entities.

3. You must promptly update us of any changes to the customer information provided to us within five (5) days of effecting such changes.

4. OmegaPro LTD reserves the right to refuse registration to, or to bar transactions from or to, or terminate any relationship with, any customer for any reason (or for no reason) at any time. Without limiting the generality of the foregoing, this includes, but is not limited to, anyone from or in jurisdictions that do not meet international AML standards, anyone that is a Politically Exposed Person (“PEP”) within the meaning of the AML laws and regulations, anyone on an official, governmental or intergovernmental Sanction Lists, upon reasonable request or direction of a competent enforcement authority, or, anyone that fails to meet any customer due diligence standards, requests, or requirements of OmegaPro LTD.

5. If we believe any information obtained from the User hereunder is (a) inadequate or incomplete; (b) false or misleading; (c) insufficient resulting in an inability to readily verify the same; (d) appearing on any Sanctions Lists; or e) result in suspicious activity, we may in our sole discretion either refuse or terminate the registration of such account or require such User to verify the documents submitted by it again. We may also, in our sole discretion, refuse to open any new accounts, terminate existing User accounts after giving due notice, or refuse to process any transactions on the website if we are unable to verify any information due to noncooperation by the User, or if such transactions are likely to have a material adverse effect on us for being in violation of any applicable laws or industry best-practice guidelines.

Third Party Service Provider

We may, at our sole discretion, at the time of the User registration process, request one or more appropriate third-party service provider to assist us in the authentication and verification of the documents provided by you. We also reserve the right to verify customer identity through non-documentary means or both. We may also use non-documentary means if we are still uncertain about whether we know the true identity of a User. We will use the following non-documentary methods of verifying identity: • Confirming validity of email; • Confirming validity of telephone number or bank account number; and • Confirming your location using, among others, your IP address.

Suspicious Activity

1. All transactions of which the amounts involved exceed the limits specified by local or applicable laws and industry best practices will be monitored, flagged for review and if necessary reported to our Compliance Officer.

2. In addition to the above, we may regularly monitor all transactions executed and/or attempted to be executed on our website, in order to promptly identify any suspicious activity, that may include, but not limited to, the following: • customer is reluctant to provide details of his/her identity; • customer is trying to use intermediaries to hide its identity or involvement in the transaction; • there appears to be no genuine reason for the customer using the services of OmegaPro LTD; • money is paid by a third party who does not appear to be connected with the customer; • the customer requests payment to be made to a third party who has no apparent connection with the customer; • activity that appears to be unusual due to the reason of being inconsistent with any User’s risk profile, expected usage pattern or sophistication.

Record Keeping

Records of all transactions executed by the User on our website, are kept for a period of at least 5 (five) years from the date of their completion. Additionally, copies or references to the evidence obtained of a customer’s identity are maintained for five years after the end of the customer relationship, or five years from the date when the transaction was completed.