Anti-Money Laundering Compliance Program

The purpose of this Anti-Money Laundering compliance program is to establish the general framework used by ENIGMA SERVICES LLC to combat money laundering, terrorist financing, corruption, sanctions evasion, fraud and other financial crimes.

ENIGMA SERVICES LLC is committed to reviewing its AML strategies, controls, risk assessments and objectives on an ongoing basis and to maintaining an effective risk-based compliance program.

Management, employees, contractors and agents with relevant responsibilities are expected to adhere to applicable AML, sanctions, customer due diligence, recordkeeping and reporting requirements when performing services for the company.

Adherence to this program is fundamental to the company's objective of complying with applicable anti-money laundering laws, sanctions requirements and regulatory guidance.

The company will seek to maintain controls that meet applicable minimum standards and any additional requirements imposed by regulators or supervisory authorities having jurisdiction over its activities.

Employee training is a key component of an effective AML compliance program. Appropriate personnel should receive training that reflects their responsibilities and the financial-crime risks associated with the company's business.

At a minimum, relevant training should address:

• Identification of suspicious activity and potentially structured transactions.
• Customer identification and identity verification requirements.
• Customer due diligence and enhanced due diligence.
• Transaction and recordkeeping requirements.
• Internal escalation and applicable reporting obligations.
• Sanctions and OFAC screening.
• Digital-asset and blockchain-related financial crime indicators where relevant.
• Applicable AML statutes, regulations and company procedures.

Personnel covered by the program should be required to review relevant AML policies and acknowledge completion of required training. Training and acknowledgements should be retained in appropriate company records.

Money laundering generally involves attempting to conceal or disguise the nature, location, source, ownership or control of funds or property derived from unlawful activity.

Financial criminals may use legitimate businesses, financial institutions, payment systems, digital assets, intermediaries, companies or other transactions to obscure the criminal origin or beneficial ownership of funds.

Money laundering is commonly described as involving three stages. These stages may overlap and do not necessarily occur in every case.

The Office of Foreign Assets Control is part of the U.S. Department of the Treasury and administers and enforces economic and trade sanctions based on U.S. foreign policy and national security objectives.

OFAC maintains the Specially Designated Nationals and Blocked Persons List as well as other sanctions lists and programs. Applicable U.S. persons and entities generally must comply with prohibitions and blocking requirements imposed by applicable sanctions programs.

ENIGMA SERVICES LLC intends to maintain sanctions-screening procedures appropriate to its risk profile, activities, jurisdictions and applicable legal obligations.

Personnel should be trained to identify transactions or behavior that may indicate money laundering, terrorist financing, fraud, sanctions evasion or other financial crime.

Potential indicators may include, without limitation:

• Unusual or unnecessarily complex payment methods.
• Multiple payments or transactions that appear structured to avoid identification, monitoring or reporting requirements.
• Payments originating from or benefiting unrelated third parties without a reasonable explanation.
• Unwillingness to provide complete or accurate identity, contact, source-of- funds or business information.
• Attempts to maintain an unusual degree of secrecy concerning a transaction or requests that normal business records not be created.
• Transactions that are inconsistent with the customer's known profile, expected activity, source of funds or stated purpose.
• Activity inconsistent with normal industry or business practice.
• Transactions involving high-risk jurisdictions, sanctioned persons or other heightened-risk indicators.

Required controls

Depending on applicable law, company procedures and the circumstances of the transaction, ENIGMA SERVICES LLC may:

• Require appropriate customer identification and verification.
• Request information concerning source of funds, source of wealth or transaction purpose.
• Conduct enhanced due diligence.
• Delay, decline, restrict, terminate or escalate a transaction or account when appropriate and legally permitted.
• Maintain required records.
• Make legally required reports to relevant governmental authorities.

ENIGMA SERVICES LLC intends to cooperate, when legally required and appropriate, with FinCEN, the U.S. Department of the Treasury, the Internal Revenue Service and other competent regulatory, supervisory and law enforcement authorities.

Because ENIGMA SERVICES LLC accepts cryptocurrency funding, its risk assessment should also consider digital-asset-specific activity.

Potential risk indicators may include:

• Funding from wallets or counterparties that cannot reasonably be connected to the customer.
• Exposure to sanctioned addresses, persons, entities or jurisdictions.
• Transactions associated with ransomware, theft, fraud or other known illicit activity.
• Unexplained rapid movement of assets through multiple wallets or networks.
• Use of services or transaction patterns designed primarily to obscure source, ownership or destination of funds.
• Significant activity inconsistent with the investor's known financial profile or expected account use.

The presence of a risk indicator does not by itself establish unlawful activity. Relevant facts should be evaluated using a reasonable, risk-based approach.

ENIGMA SERVICES LLC should formally designate a competent individual to serve as the company's AML Compliance Officer.

The designated individual should hold sufficient authority, independence, access to information and responsibility to implement and oversee an effective compliance program.

The Compliance Officer, together with senior management, should be responsible for:

• Implementing and administering the AML program.
• Maintaining policies, procedures and internal controls.
• Updating the program to reflect changes in risk, operations, law, regulation and regulatory guidance.
• Ensuring appropriate personnel receive required training.
• Overseeing identification, escalation, recordkeeping and reporting procedures.
• Coordinating sanctions compliance and customer due diligence controls.
• Supporting periodic independent review of the program.

Where required by applicable law or considered appropriate under the company's risk assessment, ENIGMA SERVICES LLC should arrange periodic independent testing or review of its AML compliance program.

The review should be performed by a qualified individual who is sufficiently independent of the operation being reviewed. The designated Compliance Officer should not independently test their own administration of the program.

The frequency and scope of independent review should be proportionate to the company's money laundering, terrorist financing, sanctions and broader financial crime risks.

Relevant considerations may include:

• Products and services offered.
• Customer and counterparty types.
• Geographic exposure.
• Payment and digital-asset networks used.
• Transaction volume, size and complexity.
• Transactions outside established customer relationships.
• Exposure to jurisdictions or counterparties presenting elevated money-laundering, terrorist-financing or sanctions risk.
• Applicable Treasury, FinCEN, OFAC and other regulatory guidance.

Section 352 of the USA PATRIOT Act and related Bank Secrecy Act regulations establish AML program requirements for various categories of regulated financial institutions and covered businesses.

To the extent such AML program requirements apply to ENIGMA SERVICES LLC or any particular line of business, the company's program should be reasonably designed to prevent the company from being used to facilitate money laundering or terrorist financing and to support applicable recordkeeping and reporting obligations.

These elements provide a framework for ENIGMA SERVICES LLC to develop and maintain an AML program appropriate to its activities and applicable regulatory obligations.