Coinbox Ltd. (the "Company") is committed to preventing money laundering (AML) and terrorist financing (CTF). We operate in compliance with the Prohibition on Money Laundering Law (2000), the Prohibition on Money Laundering Order applicable to financial asset service providers, the Counter-Terrorism Law (2016), and directives from the Capital Markets, Insurance and Savings Authority.

1. Mandatory Verification ("Know Your Customer" - KYC)

Before granting access to any services on the platform, every user must complete a verification process (KYC), which includes:

• Filling out complete personal details (name, ID/passport number, date of birth, address).
• Uploading a photograph of a valid, government-issued official identification document.
• A selfie for liveness checking (Liveness check).
• Declaring beneficial ownership (Beneficial Owner) and Politically Exposed Person (PEP) status.

For corporations, more extensive information will be required to understand the corporate structure and its controlling shareholders (above 25%).

2. Risk-Based Approach (RBA)

The Company manages money laundering risks using a risk-based model:

• A risk classification will be performed for every client upon opening an account.
• Based on the risk classification (e.g. exceptionally large transaction volumes or PEPs), Enhanced Due Diligence (EDD) may be required, which could ask for proof of Source of Wealth and Source of Funds.

3. Monitoring Activity and Transfers

The Company utilizes advanced systems for monitoring blockchain transactions (KYT - Know Your Transaction). If any connection to high-risk wallets or any unusual or unreasonable pattern is detected, the Company reserves the right to take all actions within its power to delay or block asset transfers.

4. Prohibited Countries and Sanctioned Entities Policy

Our services are not available to citizens and residents of high-risk global jurisdictions (such as Iran, Syria, North Korea) or entities and individuals included in international and Israeli sanctions lists (e.g. Ministry of Defense).

5. Reporting and Training

The Company is committed to submitting reports as required by law to the Israel Money Laundering and Terrorist Financing Prohibition Authority, including ordinary reports and Unusual Activity Reports (UAR). Our Compliance Officer (AMLO) regularly monitors compliance in this area and ensures that Company teams undergo appropriate training periodically.