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INTRODUCTION

Millionstarter Investment Company OLP. (hereinafter – “Millionstarter”) Anti-Money Laundering and  Know Your Customer Policy (hereinafter – “AML and KYC Policy”) is designated to prevent and mitigate possible risks of Millionarter being involved in any kind of illegal activity. Both international and local regulations require Millionstarter to  implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human  trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of  suspicious activity from its Users. This AML and KYC Policy applies to both natural and legal persons. Legal entities joining the Millionstarter ICO, which is defined as making a Millionstarter token purchase in a specific method stated in the clause 4 of this AML and KYC Policy will receive purchased tokens to their BEP-20 address after required AML and KYC procedures that include providing specific documents.

AML and KYC Policy covers the following matters:

  1. Verification procedures.

1.1. Basis

1.2. Identity verification

1.3. Anti-money laundering procedure

1.4. Authenticity verification

1.5. Right to report

1.6. Continuous basis of information verification

  1. Compliance Officer.

2.1. Definition

2.2. Duties

2.3. Law enforcement

  1. Monitoring Transactions.

3.1. Data analysis

3.2. Suspicious transactions reporting

  1. Payment methods

4.1. Metamask, payment cards

4.2. Payment cards usage control

4.3. Metamask transfer control

4.4. Address analysis

4.5. Liability

4.6. Due diligence

  1. Risk Assessment
  2. AML and KYC Policy

6.1. Acceptance

6.2. Privacy Policy

  1. Verification procedures

1.1. Basis One of the international standards for the prevention of illegal activities is Know Your Customer  (“KYC”). According to the KYC, Millionstarter establishes its own verification procedures within the  framework of anti-money laundering standards and Know Your Customer.

1.2. Identity verification

Millionstarter identity verification procedure requires the User to provide reliable  independent sources of documents, data or information (e.g. ID card, international passport, bank statement, utility bills) every time the User is requested to provide certain information. For AML and KYC Policy purposes,  Millionstarter hereby reserves the right to collect User information.

1.3. Anti-money laundering procedure

Millionstarter anti-money laundering procedure requires the User to provide information about the source of the funds the User uses to purchase Millionstarter tokens every time the User is requested to provide certain information. Millionstarter is not responsible for any errors or omissions in the  information provided by the User.

1.4. Authenticity verification

Millionstarter shall take steps to verify the authenticity of documents and information provided by Users, use all  legal methods to double-check identification information and hereby reserves the right to investigate the actions of  certain Users that have been found risky or suspicious.

1.5. Right to report

We may therefore report our suspicions regarding any activity of the users to local regulators, enforcement  bodies and other compliance bodies. Those kinds of actions have a goal of ensuring that the capital being used on  our platform has a legitimate origin and create a safeguard in case of individuals or groups wanting to allocate  their money from illegal activities on our platform.

1.6. Continuous basis of information verification

Millionstarter hereby reserves the right to verify the User’s identity on a continuous basis, especially when the  verification information has been changed or the User’s activity has been deemed suspicious, even if they have already undergone identity verification. User verification information shall be collected, stored, transferred and  protected strictly in accordance with Millionstarter Data Protection Policy and the relevant rules. Following the  verification of User’s identity, Millionstarter disclaims potential legal liability in situations where its Services  are used for illegal activities.

  1. Compliance Officer

2.1 Definition

The Compliance Officer is the person, duly authorized by Millionstarter, whose duty is to ensure the effective  implementation and enforcement of the AML and KYC Policy.

2.2 Duties

It is the Compliance Officer’s responsibility to supervise all aspects of Millionstarter token’s anti money laundering and counter-terrorist financing, including but not limited to:

  1. Collecting User’s identification information;
  2. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations;
  3. Monitoring transactions and investigating any significant deviations from normal activity;
  4. Implementing a record management system for appropriate storage and retrieval of documents, files, forms and logs;
  5. Updating risk assessment regularly;
  6. Providing law enforcement with information as required under the applicable laws and regulations.

2.3 Law enforcement

The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money  laundering, terrorist financing and other illegal activity.

2.4 Contact with the clients and authorities

The Compliance Officer is obliged to communicate effectively with the  clients and authorities having any complaints or questions that are being addressed to him regarding the Quarashi  Network AML and KYC Policy as also its implementation in order to ensure the transparency and credibility of the  platform. The address to contact the Compliance Officer is . Any kind of correspondence  sent to the Compliance Officer will be addressed by him within the time frame of 5 working days.

  1. Monitoring transactions

3.1 Data analysis

User verification is carried out not only by checking their identity, but also by analyzing transaction models. Millionstarter therefore relies on data analysis as a tool for assessing risk and identifying suspicions. Millionstarter carries out many regulatory compliance tasks, including data collection, filtering and record keeping.

3.2 Suspicious transactions reporting

With regard to the AML and KYC Policy, Millionstarter will monitor all transactions, and it reserves the right to ensure  that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer and  request the User to provide any additional information and documents in case of suspicious transactions. Compliance Officer will monitor User’s transactions on a day-to-day basis in order to define whether such  transactions are to be reported and treated as suspicious or are to be treated as bona fide.

  1. Payment methods

4.1 Trust Wallet, Bank Transfer, PayPal, Credit Card Payment

The User may purchase Millionstarter tokens by linking Trust Wallet and managing the BNB deposit, transferring any cryptocurrency or by card or wire transfer. To carry out a transaction in a chosen way,  the User must follow the relevant instructions on the Millionstarter site.

4.2 Payment cards usage control

Millionstarter may refuse to complete or block, cancel or reverse a transaction of the Millionstarter purchase

made with payment cards usage if the User is suspected of money laundering, terrorist financing, fraud, any other  financial crime, or any other illegal action. Millionstarter is under no obligation to disclose the details of its credit card risk management and security procedures to the User.

4.3 Trust Wallet transfer control

Millionstarter may refuse to complete or block, cancel or reverse a transaction of the Millionstarter token purchase made with the usage of Trust Wallet (DApps Platform, Inc. 548 Market St PMB 96630 San Francisco, California 94104-5401 US) if the User is suspected of money laundering, terrorist financing, fraud, any other financial crime, or any other illegal action.

4.4 Address analysis

Millionstarter may analyze the cryptocurrency addresses against common black lists and known security  discrepancies, to ensure that the funds do not come from illicit sources, and there are no signs of money  laundering (location, layers, integration),either manually or using a third-party service.

4.5 Liability

Millionstarter has no control over, or liability for, the delivery, quality, safety and legality or any other aspect  of any goods or services received or purchased from Metamask.

  1. Risk assessment

Millionstarter, in accordance with international requirements takes a risk-based approach to combating money  laundering and the financing of the terrorism. By applying a risk-based approach, Millionstarter can ensure that  measures to prevent or mitigate money laundering and terrorist financing are proportionate with the identified risks. This makes it possible for resources to be allocated in the most efficient way. The principle is to allocate  resources corresponding to priorities so that the highest risks are given the closest attention.

  1. AML and KYC Policy

6.1 Acceptance

By joining the Millionstarter ICO, which is defined as making a Millionstarter token purchase in a specific method stated in the clause 4 of this AML and KYC Policy, the User accepts the terms of this AML and KYC Policy  and hereby agrees to have read, understood and accepted the Terms of Use and Data Protection Policy available at: https://millionstarter.com/term-of-use. In addition, when using certain services, the User may be subject to

additional agreements applicable to such services. The User must stop using the services and the website if they do not agree with the AML and KYC Policy and the Terms of Use and Data Protection Policy.

6.2 Privacy policy

User’s identification information will be collected, stored, shared and protected strictly in accordance with the Millionstarter Privacy Policy and related regulations.