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KYC/AML Policy

Atlas Pre-Seed Programme · Administered via SWC Field (KEYSTRA Ltd.)

KYC/AML Policy

Effective Date: 26 August 2026

1. Responsible Parties

The Administrator arranges KYC before acceptance of the Offer and uses Veriff for identity verification. Every purchase is subject to AML screening. The Seller makes the final compliance decision concerning performance of the agreement and may request additional documents.

2. Information Subject to Verification

The following may be verified to the extent necessary for risk assessment and compliance with the law: identity, date of birth, address, identity document, biometric matching, source of funds, beneficial owner, authority of a representative, sanctions exposure, politically exposed person (PEP) status and adverse information.

3. Consequences

Acceptance and transfer may be unavailable until verification has been successfully completed. If a risk is identified, the transaction may be suspended, rejected or terminated; information may be retained and disclosed to competent authorities where required by law.

Any refund following termination due to a breach shall be processed in accordance with mandatory provisions of UAE law, subject to lawful restrictions on the transfer of blocked funds.

4. Retention and Safeguards

Verification data is retained only for as long as necessary for compliance purposes, the protection of rights and satisfaction of mandatory requirements. Access is restricted to authorised persons and service providers.

Published programme document. If a later signed version is issued by the parties, that version prevails in case of conflict.