GlobuyDirect is strongly committed to complying with Anti-Money Laundering (AML) AML) and Countering the Financing of Terrorism, CFT) laws and regulations. We take it as our responsibility to maintain the integrity and security of the financial system and will not tolerate any use of our services for illegal money laundering or terrorist financing.

In order to effectively comply with our legal obligations and ethical responsibilities, we have established a robust and continuously improving AML/CFT compliance system, with core elements including:

1. Policies & Procedures
   Develop and strictly enforce AML/CFT that complies with international standards (e.g., FATF recommendations) and local regulations Policies, procedures and internal control systems.

2. Customer Due Diligence:

   • Identification & Verification:
     Implement strict identification and verification procedures (Know Your Customer, KYC) for all customers. This may require you to provide identification documents (such as passport, ID card), proof of address, etc.

   • Continuous monitoring:
     Continuously monitor customer trading activities and identify abnormal or suspicious behaviors that are inconsistent with the nature and risk profile of the customer's business.

   • Risk-based:
     Risk assessment based on factors such as customer type, nature of business relationship, geography, etc., and enhanced due diligence (EDD) measures for high-risk customers.

3. Transaction monitoring
   utilizes a combination of advanced technology and human review to monitor transactions in real-time and retrospectively to identify potentially suspicious patterns.

4. Suspicious Activity Reporting
   Establish a clear process for reporting any suspicious transactions or activities to the relevant financial intelligence unit (e.g., the China Anti-Money Laundering Monitoring and Analysis Center in China) as soon as it becomes aware of it.

5. Sanctions List Screening
   Screening of all clients and counterparties to ensure that they are not involved in international and domestic sanctions lists (e.g. UN, OFAC, EU, Ministry of Public Security of China, etc.).

6. Record Keeping
   Properly keep all customer identity information, transaction records, and documents related to due diligence, monitoring, and reporting in accordance with the law.

7. Employee training
   Conduct AML/CFT on a regular basis for all relevant employees Training on regulations, company policies, identification skills and the latest risk trends to ensure that they have the ability and awareness to fulfill their compliance responsibilities.

8. Independent Audits
   Regularly undergo internal or external independent audits to assess the effectiveness of the AML/CFT system and make necessary improvements.

In order to jointly maintain a safe and compliant financial environment, you are responsible for using GlobuyDirect's services to:

• Provide true and accurate information:Provide complete, true and accurate identity and business information during the account opening and business relationship, and update any changes in a timely manner.

• Cooperate with due diligence: Actively cooperate with our customer identification, verification and ongoing due diligence requirements, and provide relevant supporting documents and information as required.

• Compliant use of services:Ensure that your funds are from a legitimate source and that the purpose of the transaction is genuine, legal and compliant. GlobuyDirect may not be used services for any illegal activities, including but not limited to money laundering, terrorist financing, fraud, tax evasion, etc.

• Report suspicious behavior: If you notice any suspicious activity or have questions about your requirements, please contact us.

1. Provide clear and transparent AML/CFT policy information.
2. To protect your privacy and information security (subject to legal and regulatory requirements).
3. Strive to strike a balance between compliance requirements and customer experience.
4. Set up a dedicated channel to handle your AML/CFT-related inquiries or reports.

1. Right to object: GlobuyDirect reserves the right to refuse and fail to meet AML/CFT The right to request or be deemed to be a high risk customer/transaction to enter into a business relationship or to continue a business relationship.
2. Obligation to Cooperate: We are legally obligated to cooperate with regulatory and law enforcement investigations.
3. Disclaimer: The content of this column is for general purposes only and does not constitute legal advice. The specific obligations are subject to the relevant laws and regulations and the agreement we have signed with you.

If you have any questions about GlobuyDirect's anti-money laundering policies or procedures, or need to report suspicious activity, please contact our Compliance Department at:

• E-mail： admin@globuydirect.com