Anti-Money Laundering and Counter Terrorist Financing Policy

Premiumreal Technologies Inc. is dedicated to combating money laundering and adhering to the text and spirit of anti-money laundering laws in the countries and jurisdictions where it operates. Premiumreal Technologies Inc. understands that as an international financial services company, it bears significant responsibility in the fight against money laundering. No customer relationship is worth jeopardizing our commitment to money laundering prevention.

As a result, Premiumreal Technologies Inc. policy is to take all reasonable and appropriate steps to prevent people involved in money laundering, fraud, or other financial crimes, including the financing of terrorists or terrorist operations (collectively referred to as "money laundering") from using Premiumreal products and services.

Our Mission Statement
The following are the goals of Premiumreal's AML/CFT policy:
● Ascertain that Premiumreal Technologies Inc. follows all applicable laws, regulations, and standards, as well as sound and recognized monetary policies.
● Ascertain that Customers, Premiumreal, Banks, Nations are not victims of unlawful actions committed by its clients.
● Ascertain that an effective policy exists to defend Premiumreal's good name and reputation.
● Ensure that the policy does not compromise Premiumreal's positive relationship with its loyal customers.


For the purpose of this policy, the following terms shall have the meaning set out below:
● Board means the Board of the Premiumreal Technologies Inc.
● Counterparty is any party that contributes to, executes, implements, bids for, or in any way participates in, Premiumreal related Activities, including receiving or sending money or other form of financing or support using the Premiumreal platform.
● Know Your Customer (KYC) is a process to identify and verify the true identity of the Counterparty. This would enable Premiumreal to assess and evaluate the extent of Money Laundering/Terrorist Financing (ML/TF) risk associated with the proposed Counterparty.
● Covered Individuals means individuals working at any level or grade within the Premiumreal Technologies Inc., including (but not limited to) the Executive Director, management and staff of Premiumreal Technologies Inc., and other individuals contracted by the Premiumreal Technologies Inc.
● Financing of Terrorism or Terrorist Financing (TF) is defined as the commission of any offence as set out in Article 2 of the International Convention for the Suppression of the Financing of Terrorism.
● Money Laundering (ML) refers to:
The conversion or transfer of property, knowing that such property is derived from crime, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of the crime to evade the legal consequences of his or her actions;
The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing such property is derived from crime, or;
The acquisition, possession or use of property, knowing at the time of receipt that such property was derived from a criminal offense.
● Risk Based Approach (RBA) to AML/CFT is the process of identifying, assessing and understanding ML/TF risks to which Premiumreal Technologies Inc. is exposed and to take measures commensurate with those risks to mitigate them effectively.
● Tipping-Off means disclosing the fact to the Counterparty that a suspicious transaction or related information is filed with management or the authorities.
● Whistle Blowing (also written as whistle-blower or whistle blower) is a person, often an employee, who reveals information about activity within a private or public organization that is deemed illegal, immoral, illicit, unsafe or fraudulent, and in this context Money Laundering-ML and Financing Terrorist-FT.


Premiumreal Technologies Inc. is committed to the highest ethical standards regarding anti-money laundering (AML) and countering the financing of terrorism (CFT) consistent with the Financial Action Task Force (FATF) recommendations in its “International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation”. This AML/CFT Policy intends to protect Premiumreal Technologies Inc. from money laundering (ML) and terrorist financing (FT or TF). The Policy lays forth the concepts and basic criteria for internal AML/CFT controls that Premiumreal Technologies Inc. should follow in order to avoid reputational, regulatory, legal, and financial risks.

Applicability and scope;
Premiumreal Technologies Inc.'s staff, governing bodies, and everyone else who works for the Premiumreal Technologies Inc (i.e. Covered Individuals) are required to follow this Policy in order to protect the Premiumreal Technologies Inc. and its reputation from being used for Money Laundering-ML and/or Finance Terrorist-FT by ensuring that they carry out their responsibilities in a way that allows the Policy to be fully implemented.
Premiumreal shall take steps to encourage its counterparties to adopt policies and procedures that are consistent with the principles set out in this Policy, with the purpose of safeguarding Premiumreal platform/resources from being used for Money Laundering or the Financing of Terrorism.
The goal and the purpose
The purpose of the policy is to provide principles and guidance on AML/CFT requirements and risks in order to achieve the following objectives: Prevent the Premiumreal remittal platform from being used for Money Laundering (ML) and/or Terrorist Financing (FT).
In nations where Premiumreal and its Counterparties operate, comply with applicable legal requirements and international standards.
Reduce any potential damage to company reputation; Support developing countries in their way of living and at same time upgrading their capacities to fulfill the International AML/CFT fiduciary standards.
Avoid forming any relationships or engaging in any transactions that may be related to or enable Money Laundering-ML, Financing Terrorist-FT, or any other illegal conduct.
Exercise extreme caution when dealing with Transactions, those authorized to act on their behalf, and linked parties of the Transactions.
Review and update its AML/CFT Policy and accompanying AML/CFT Standard on a regular basis as threats and international standards for preventing and detecting ML and/or FT evolve.

Key provisions
To identify, assess, and comprehend its ML and TF risks, Premiumreal Technologies Inc. will adopt and implement a continuous risk-based approach (RBA). It must also ensure that the steps taken to minimize ML and/or TF are proportionate to the risks identified, allowing it to make the best judgments possible about how to allocate its resources.

In order to manage AML/CFT risk, it will take the following steps:
Due diligence;
● Premiumreal will use Customers Due Diligence (CDD) and/or Know Your Customer (KYC) measures that are risk-based and take into account the type of counterparty, counterparty relationship, financial instrument, and country of business.
● Prior to entering into a counterparty arrangement, Premiumreal must identify and verify the identification of its Counterparties (including their beneficial owners).

Counterparty Relationship:
To avoid being involved in arrangements constructed for the purposes of Money Laundering-ML and Financial Terrorism-FT, Premiumreal shall take reasonable means to analyze the purpose, economic reasoning, and overall AML/CFT and related integrity issues of the Counterparty and its Beneficial Owners. Premiumreal will not engage with, and will terminate any existing Counterparty relationship with; Counterparties who refuse to cooperate with Premiumreal's KYC efforts;
Counterparties who engage in activities prohibited by Premiumreal's Policy on Prohibited Practices; or
Counterparties who are currently subject to any financial sanctions imposed by international bodies.

Monitoring: Premiumreal Technologies Inc’s. Anti-Fraud Unit will be in charge of monitoring the policy's execution.
Reporting: Any suspicious information or red flag that comes to a Covered Individual's attention that indicates ML/TF must be immediately reported to FINTRAC of Canada and any other appropriate authorities by Premiumreal Technologies Inc. Anti-Fraud Unit, without contacting the Counterparty or other third parties ('Tipping Off').

Premiumreal must keep all documents collected through KYC processes and documentation about counterparty relations and executed transactions, as well as correspondence with the Counterparty, for at least 5 (five) years.
Confidentiality: Premiumreal will maintain the confidentiality of information on Counterparties and transactions collected in the course of complying with AML/CFT obligations.
Implementation: Premiumreal shall provide further documentation and advice (AML/CFT Standard or Procedures) to help Covered Individuals better understand and apply this Policy.
Evaluate: Premiumreal shall review and examine its AML/CFT Policy, as well as maintain an effective implementation of the AML/CFT Policy for Premiumreal's activities, in accordance with worldwide best practices and changing FATF Recommendations.

Key responsibilities

Board: The Board is in charge of ensuring the Premiunreal's risk management framework and procedures for ML and FT are governed and overseen.
Internal Audit: In accordance with its own mission, the Internal Audit unit shall give such support as the competent authorities may demand to monitor adherence to the AML/CFT Policy.
Premiumreal Secretariat: Premiumreal Secretariat shall work together with the relevant authorities to ensure that this policy is implemented effectively, with tasks assigned in accordance with their respective mandates.
Personnel of Premiumreal Technologies Inc. and its associates: Staff personnel, consultants, and other associates are responsible for the following: (a) Adherence to Premiumreal's anti-money laundering and counter-terrorist financing policy, standards, and controls;
(b) Familiarizing themselves with applicable Premiumreal processes and procedures for managing AML/CFT compliance and acting in accordance with them; and
(b) Reporting any suspicions (or actual occurrences) or red flags of ML/TF actions to the relevant Government authority without delay.


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