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      Doo Prime Vanuatu Limited Anti-Money Laundering and Know Your Customer Policy

      Doo Prime Vanuatu Limited (referred as “Doo”, we, us or our ) combats against any forms of money laundering, related money laundering, terrorist financing or criminal activities with strong dedication to fully comply with the laws and regulations on Anti-Money Laundering (AML) in Cayman Islands, and comply with the laws and regulations on Money Service Operators preventing money laundering while undertaking any money-related transactions.

      Doo has established a series of AML procedure for the compliance of “The Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance” and will apply the following AML and KYC procedures in all money-related transaction:

      1. Customer Due Diligence

      Doo has established a Know-Your-Customer (KYC) policy to verify the identities of all our customers and to the largest degree to ensure a reasonable level of certainty. This will include but not limit to our retail customers, business partners, the board members and shareholders.

      Doo will collect and verify a list of necessary documents as below if there is any necessary, including but not limited to the identity document featuring with a matching photo and provided information issued by government; a valid address proof, such as original recent utility bill, or government issued document with the same and address matching the provided information; and other forms of identity confirmation if there is any necessary.

      In the identity verification process, we will request the original copy or clear and colored scanned copy; we may also request more than one identity documents for crossing verification if we deem necessary.

      The required document lists are as below including but not limited to:

      1.1 Identity certification:
      a) Resident Identity Card, or
      b) Passport, or
      c) Driver License, or
      d) Social Insurance ID Card, or
      e) Other valid identity card issued by the government or related authorities

      1.2 Address Proof:
      a) Credit Card Bill, or
      b) Utility Bill, or
      c) Certification issued by landlord, or
      d) Other valid materials proved the resident address

      If it fails to verify the identity with reasonable certainty, we will not establish business partnership or proceed with any further transactions. If the customer either refuses to provide the required information, or provide unauthentic information, we will terminate the business partnership or reject the requested transactions.

      If we deem any suspicion on identity verification of customers, we shall conduct a Suspicious Transaction Report (STR) to The Cayman Islands Monetary Authority (CIMA) if it is necessary.

      2. Ongoing Monitoring

      Doo will take a risk-based approach and conduct ongoing monitoring of business relationships with customers to ensure that all related are up to date. Whenever there is suspicion, the customer will be required to identify and verify the source or destination of the transactions, whether they be individuals or company beneficial owners.

      Doo will not accept high-risk customers that are identified as follows:

      • Customers with business that handles large amount of cash or complex unusually large transactions, which could not be verified.
      • Customers with large one-off transactions, or a number of transactions carried out by the same account within a short period of time.
      • Customers based in or conducting business in or through, a high-risk jurisdiction, or a jurisdiction with known higher levels of corruption, organized crime or drug production or distribution.
      • Transactions with the source funds that cannot be verified.
      • Transactions that have no apparent economic or legitimate purpose.

      3. Record Keeping

      Records of all original and copied identity verification documents, all submitted documents of Suspicious Transactions Reports (STR), together with any supporting documents will be complied and filed with confidentiality and security in Doo for any further requiring.

      4. Reporting of suspicious customers and transaction activities

      Doo pledges that if there are any suspicion in the transactions process of customers, a STR will be submitted to The Cayman Islands Monetary Authority (CIMA) as soon as it is reasonable to do so.

      5. AML training

      Firstly, all affected staff in Doo will be provided with related policy and knowledge training that explains laws and regulations on Anti-Money Laundering (AML) in Cayman Islands, and the whole process of Customer Due Diligence. In addition, all affected staff in Doo will be clearly clarified in their job descriptions and will be trained on their responsibilities in relation to money laundering transactions, and are aware of how to identify and deal with transactions that may involve money laundering.