Anti-Money Laundering (AML) Policy

1. Introduction and Purpose

This Anti-Money Laundering (AML) Policy outlines the commitment of ITAI TECH LTD (“the Company”) to preventing its platform, undress.cc, from being used for money laundering, terrorist financing, or any other form of illicit financial activity.

The Company complies with the requirements of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended; the Proceeds of Crime Act 2002; the Terrorism Act 2000; and relevant guidance issued by the Financial Conduct Authority (FCA) and the Financial Action Task Force (FATF).

The purpose of this Policy is to:

• Establish internal controls and procedures to detect and deter money laundering and terrorist financing;

• Ensure compliance with UK regulatory obligations;

• Promote a culture of transparency and responsibility across all levels of operation.

2. Definitions

Platform: undress.cc, an AI-powered content platform for adult users (18+) offering digital and AI-generated services.

User: Any individual or entity registered or transacting on the platform.

Tokens: Digital assets or credits used within the platform to access premium services or content.

Payment Provider: Any licensed and KYC-compliant third-party partner through which the Company processes payments in fiat or cryptocurrency.

Suspicious Activity: Any transaction or behaviour that lacks a clear lawful purpose, deviates from a user’s established pattern, or raises suspicion of money laundering or terrorist financing under the Proceeds of Crime Act 2002.

3. Responsibilities of the Platform Operator

ITAI TECH LTD shall:

• Conduct all transactions exclusively through licensed and KYC-verified payment providers;

• Avoid direct peer-to-peer or unverified user-to-user token transfers;

• Require all payment partners to maintain AML/CTF policies consistent with UK and FATF standards;

• Maintain internal oversight to identify and mitigate AML risks;

• Reserve the right to suspend, block, or terminate any transaction or account that appears connected to illicit or high-risk activity.

4. Customer Identification (KYC) Policy

The Company applies a risk-based approach to customer identification.

While general use of the platform may not require identity verification, ITAI TECH LTD reserves the right to request Know Your Customer (KYC) documentation when:

• A transaction exceeds defined thresholds or presents unusual characteristics;

• A payment partner or regulator requests enhanced due diligence;

• The source or purpose of funds is unclear;

• Repetitive or high-value crypto transactions occur.

Required documentation may include:

• A valid government-issued ID;

• Proof of address;

• Information on the source of funds or wealth.

Access to platform features may be restricted until the verification process is successfully completed.

5. Transaction Monitoring

The Company employs continuous transaction monitoring to identify irregularities and prevent misuse of its systems.

Monitoring procedures include:

• Detection of abnormal transaction sizes, frequencies, or structures;

• Screening of transactions against UK and international sanctions lists (OFSI, UN, EU, HM Treasury);

• Identification of activity involving high-risk or non-cooperative jurisdictions;

• Review of user activity patterns for anomalies suggesting layering or structuring.

The Company uses a combination of automated checks and manual reviews to ensure accurate monitoring and escalation.

6. Reporting of Suspicious Activity

If suspicious activity is identified, ITAI TECH LTD will:

• Restrict or suspend the related accounts or transactions;

• Conduct an internal review under the supervision of the AML Officer;

• File a Suspicious Activity Report (SAR) to the UK National Crime Agency (NCA) in accordance with the Proceeds of Crime Act 2002 and Terrorism Act 2000;

• Maintain confidentiality in all cases, ensuring that users are not informed of any reporting action (tipping-off prohibition).

All reports and related data will be handled in compliance with UK GDPR and stored securely.

7. Designated AML Compliance Officer

The Company designates the following individual as its AML Compliance Officer (Money Laundering Reporting Officer, MLRO):

Name: Anastasija Provotorova

Title: Director

Email: [email protected]

Responsibilities:

• Overseeing the implementation and effectiveness of this AML Policy;

• Reviewing and approving internal procedures;

• Receiving and assessing internal reports of suspicious activity;

• Submitting SARs to the National Crime Agency (NCA);

• Acting as the main liaison with regulatory and law enforcement authorities.

8. Staff Responsibility and Training

All employees and contractors with access to financial data or user information are required to understand and comply with AML obligations.

The Company provides regular AML/CTF awareness training covering:

• Indicators of suspicious transactions;

• Escalation and reporting procedures;

• Responsibilities under UK law and internal policy.

Failure to comply with AML standards or to report suspicious behaviour may result in disciplinary action and possible referral to law enforcement.

9. Record Keeping

The Company keeps all relevant records for a minimum of five (5) years following the completion of a transaction or termination of a user relationship, whichever is later.

Records include:

• Transaction details and payment logs;

• User KYC documentation (where applicable);

• Copies of internal investigations and SARs.

All data is encrypted and stored securely, accessible only to authorised compliance personnel.

10. Policy Review

This AML Policy is reviewed annually or earlier if:

• There are changes in UK AML/CTF legislation or FATF recommendations;

• The Company introduces new services or technologies;

• A review is requested by a regulator, bank, or payment partner.

Any updates are approved by the Director and communicated to all relevant staff.