AML & KYC Policy

1. Purpose

The purpose of this Anti-Money Laundering (“AML”) and Know Your Customer (“KYC”) Policy is to establish Bosse Value Network’s framework for identifying customers, assessing risk, preventing fraud, and supporting compliance with applicable laws and the requirements of our payment processors and financial partners. This Policy is designed to protect BVN, its users, merchants, business partners, and the integrity of the Platform.

2. Scope

This Policy applies to:

Individual Users Business Accounts Merchant Accounts Enterprise Customers Platform Administrators Employees Contractors Authorized Representatives Third-party vendors involved in identity verification or fraud monitoring

The Policy applies to all products and services offered through BVN.

3. AML Compliance Commitment

BVN is committed to maintaining a risk-based compliance program designed to:

Prevent money laundering Prevent terrorist financing Detect fraud Protect customer accounts Support lawful business activity Meet contractual obligations with payment processors and banking partners

BVN reviews its compliance procedures periodically and may update them as legal or operational requirements evolve.

4. Customer Identification Program (CIP)

4.1 Identity Verification

Before enabling certain features or lifting account restrictions, BVN may verify a user’s identity. Verification may include:

Full legal name Date of birth Residential address Email address Telephone number Government-issued identification Selfie verification Proof of address

4.2 Verification Timing

Identity verification may be requested:

During registration Before point conversion Before redemption requests Before higher transaction limits During fraud investigations When account information changes When required by law or contractual obligations

4.3 Verification Outcomes

Following review, BVN may:

Approve verification Request additional information Restrict account functionality Delay certain transactions Decline verification where requirements are not met

5. Customer Due Diligence (CDD)

BVN applies customer due diligence measures to better understand users and business customers. CDD may include:

Verifying identity Confirming contact information Assessing account activity Reviewing transaction patterns Evaluating geographic risk Understanding the intended use of the Platform

The level of due diligence applied may vary depending on the assessed risk.

6. Enhanced Due Diligence (EDD)

Enhanced Due Diligence may be conducted for higher-risk accounts. EDD may include:

Additional identity verification Requests for supporting documentation Source-of-funds inquiries where appropriate Review of business activities Senior compliance review Ongoing monitoring

EDD may be applied based on risk indicators rather than automatically for all users.

7. Business Verification

Business Accounts may be required to provide:

Legal business name Business registration documents Employer Identification Number (EIN) or applicable tax identifier Business address Authorized representative information Supporting documentation reasonably requested by BVN

Verification helps ensure that business accounts are legitimate and authorized to participate in the Platform.

8. Beneficial Ownership

Where appropriate, BVN may request information regarding individuals who own or control a business customer. Information may include:

Ownership percentages Control persons Authorized representatives Verification of identity

9. Sanctions Screening

BVN may screen users, businesses, and transactions against applicable sanctions lists maintained by governmental authorities. If a potential sanctions match is identified, BVN may:

Pause onboarding Restrict transactions Request additional information Conduct further review Take action as required by applicable law

10. Politically Exposed Persons (PEPs)

Where appropriate and supported by our service providers, BVN may identify accounts associated with Politically Exposed Persons (PEPs) or individuals presenting elevated compliance risk. Additional review may be conducted before providing certain services.

11. Risk-Based Customer Classification

BVN may classify customers using a risk-based approach that considers factors such as:

Identity verification status Account history Transaction activity Geographic considerations Business type Fraud indicators Previous compliance reviews

Risk classifications help determine the level of monitoring and review applied to an account.

12. Transaction Monitoring

BVN may monitor Platform activity to identify unusual or potentially unauthorized behavior. Monitoring may include:

Reward Point issuance Point transfers Point conversions Redemption requests Payment activity Login behavior Device changes

• Velocity checks
• Geographic inconsistencies

13. Suspicious Activity Monitoring

BVN may review activity that appears inconsistent with normal account behavior. Examples include:

Rapid accumulation of Reward Points High-volume transfers Multiple linked accounts Repeated failed verification attempts Unusual redemption patterns Device or IP anomalies Potential abuse of promotions

Activity identified for review may be referred to the Compliance Team for further assessment.

14. Fraud Detection

BVN employs a combination of automated systems and manual reviews to help detect:

Account takeover attempts Identity theft Payment fraud Promotion abuse Unauthorized transactions Platform manipulation

Where appropriate, additional verification or temporary restrictions may be applied while a review is underway.

15. Account Restrictions

BVN may temporarily limit or suspend account functionality when necessary to:

Complete identity verification Investigate suspicious activity Address security concerns Comply with legal obligations Protect users and the Platform

Restrictions are applied based on the circumstances of each case and are reviewed by authorized personnel.

16. Internal Investigations

Potential fraud, policy violations, or compliance concerns may be investigated by authorized BVN personnel. Investigations may include reviewing:

Transaction history Login activity Device information Communications with customer support Documentation provided by the user

Users may be asked to cooperate by providing additional information.

17. Recordkeeping

BVN maintains records necessary to:

Support fraud investigations Respond to disputes Meet legal and regulatory obligations Demonstrate compliance with contractual requirements Maintain accurate business records

Records are retained in accordance with applicable law and BVN’s Data Retention Policy.

18. Employee Training

Personnel responsible for fraud prevention, customer support, compliance, or account reviews receive training appropriate to their roles. Training topics may include:

Fraud indicators Identity verification procedures Privacy obligations Information security Escalation procedures

19. Independent Reviews

BVN may periodically evaluate its AML/KYC program through internal assessments or independent reviews to identify opportunities for improvement and to support ongoing compliance efforts.

20. Reporting Procedures

Where required by applicable law, BVN may cooperate with lawful requests from regulators, law enforcement, or other competent authorities. Reports or disclosures will be made only when legally required or otherwise authorized by law.

21. Regulatory Cooperation

BVN may respond to lawful requests for information from government agencies, courts, or regulatory authorities and may preserve records as required by applicable law.

22. Policy Updates

BVN may revise this AML/KYC Policy to reflect changes in:

Laws and regulations Platform functionality Fraud trends Business operations Payment processor requirements Industry best practices

Updated versions become effective on the date specified in the revised Policy.

23. Contact Information

Compliance Team Bosse Value Network (BVN) Compliance Email: [email protected] Support Email: [email protected] Website: https://www.bossevaluenetwork.com Business Address: 650 Hidden Valley Club Dr, Ann Arbor, MI 48104, United States