Meta Bliss Group B.V. ("Company," "we," "us," or "our"), Registration No. 159718, with its registered office at Korporaalweg 10, Willemstad, Curacao, is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering and Know Your Customer Policy ("AML/KYC Policy") outlines our procedures for compliance with applicable anti-money laundering laws and regulations.

The Company is a wholly-owned subsidiary of 36 Group AB, a company listed on the NGM Nordic SME exchange (ticker: 36GRP).

1. Regulatory Framework

The Company's AML/KYC procedures are designed to comply with the following regulatory frameworks and standards:

Curacao Legislation: The National Ordinance on the Identification of Clients When Providing Services (Landsverordening identificatie bij dienstverlening, "LID"), the National Ordinance on the Reporting of Unusual Transactions (Landsverordening melding ongebruikelijke transacties, "LMOT"), and related subsidiary legislation applicable in Curacao;
FATF Recommendations: The international standards on combating money laundering and the financing of terrorism and proliferation as published by the Financial Action Task Force ("FATF"), including the FATF's updated guidance on virtual assets and virtual asset service providers;
EU AML Directives: Although the Company is incorporated in Curacao, the Company applies principles aligned with the European Union's Anti-Money Laundering Directives (including the Sixth Anti-Money Laundering Directive, "6AMLD") as best practice, given its parent company's listing in Sweden;
Sanctions Compliance: The Company screens all Users and transactions against applicable sanctions lists, including those maintained by the United Nations Security Council, the United States Office of Foreign Assets Control ("OFAC"), the European Union, and Her Majesty's Treasury ("HMT").

2. Risk-Based Approach

The Company adopts a risk-based approach to AML/KYC compliance, as recommended by the FATF. This means that we assess the money laundering and terrorist financing risks associated with our business activities, our customers, and their transactions, and apply appropriate measures proportionate to those risks.

Our risk assessment considers the following factors:

Customer Risk: The nature and profile of the customer, including their geographic location, the nature of their business or employment, their transaction patterns, and the source of their funds;
Product/Service Risk: The inherent risk associated with the products and services offered by the Platform, including the potential for anonymity, cross-border transactions, and high-value trades;
Geographic Risk: The risk associated with the jurisdictions in which our customers are located, taking into account FATF country risk assessments and relevant international designations;
Transaction Risk: The risk associated with specific transaction types, volumes, and patterns, including unusual or suspicious activity;
Channel/Delivery Risk: The risk associated with how our services are delivered, including the non-face-to-face nature of online interactions and the use of blockchain technology.

3. Customer Identification

3.1 Standard Customer Due Diligence (CDD)

The Company applies standard CDD measures in situations requiring identity verification, which may include but are not limited to:

When a User's cumulative transaction volume exceeds defined thresholds;
When a User requests access to certain features or services;
When there is a suspicion of money laundering or terrorist financing;
When the Company has doubts about the veracity of previously obtained identification data.

Standard CDD requires the following information:

Full legal name;
Date of birth;
Nationality;
Residential address;
Government-issued photo identification document (passport, national ID card, or driver's license);
Proof of residential address (utility bill, bank statement, or government correspondence dated within the last 3 months).

3.2 Enhanced Due Diligence (EDD)

Enhanced due diligence measures are applied in higher-risk situations, including:

Politically Exposed Persons (PEPs) and their family members or close associates;
Users from higher-risk jurisdictions as identified by FATF or the Company's own risk assessment;
Users with complex or unusual transaction patterns;
High-value transactions exceeding specified thresholds;
Any situation where the standard CDD measures are insufficient to mitigate the identified risk.

EDD may require additional information, including:

Source of funds documentation;
Source of wealth documentation;
Purpose and intended nature of the business relationship;
Enhanced ongoing monitoring of the business relationship;
Senior management approval for establishing or continuing the business relationship.

3.3 Wallet-Based Due Diligence

Given the nature of the Platform, the Company also applies blockchain-specific due diligence measures, including:

Wallet Screening: Screening of wallet addresses against known blacklists, sanctions lists, and databases of addresses associated with illicit activity;
Transaction Monitoring: Monitoring of on-chain transaction patterns for suspicious activity, including interactions with known mixing services, sanctioned addresses, or high-risk protocols;
Blockchain Analytics: Use of third-party blockchain analytics tools to assess the risk profile of wallet addresses and trace the provenance of funds;
Wallet Ownership Verification: In cases where CDD or EDD is required, verification that the User controls the wallet address through cryptographic signature verification.

4. Ongoing Monitoring

The Company conducts ongoing monitoring of User activity to detect and report suspicious transactions. This includes:

Automated transaction monitoring systems that flag transactions based on predefined rules and risk indicators;
Regular review and updating of customer risk profiles;
Periodic rescreening of Users against updated sanctions lists and PEP databases;
Investigation and escalation of flagged transactions and activities.

5. Suspicious Activity Reporting

Where the Company identifies activity that is suspicious or unusual, it will:

Conduct a thorough internal investigation;
File a Suspicious Transaction Report (STR) or Unusual Transaction Report (UTR) with the relevant Financial Intelligence Unit (FIU), as required by applicable law;
Cooperate fully with law enforcement and regulatory authorities;
Take appropriate action, which may include restricting, suspending, or terminating the User's access to the Platform.

The Company will not inform the User that a suspicious activity report has been filed ("tipping off") where prohibited by law.

6. Record Keeping

The Company maintains records of all CDD and EDD documentation, transaction records, and suspicious activity reports for a minimum period of five (5) years after the end of the business relationship or the date of the transaction, or longer if required by applicable law. Records are stored securely with appropriate access controls.

7. Employee Training

All relevant employees and contractors receive regular training on AML/KYC obligations, including:

The legal and regulatory framework applicable to the Company;
The Company's AML/KYC policies and procedures;
How to identify and report suspicious activity;
The risks specific to digital assets and blockchain-based services;
Individual employee obligations and the consequences of non-compliance.

8. Compliance Officer

The Company has appointed a designated Compliance Officer (also referred to as the Money Laundering Reporting Officer, or "MLRO") who is responsible for overseeing the implementation and effectiveness of the AML/KYC program. The Compliance Officer reports directly to senior management.

9. Contact Information

If you have any questions about this AML/KYC Policy, or if you wish to report suspicious activity, please contact us at:

Email: legal@blizzmarkets.com
Support: support@blizzmarkets.com
Company: Meta Bliss Group B.V., Korporaalweg 10, Willemstad, Curacao