Anti-Money Laundering (AML) Policy

Effective Date: May 1, 2025

Dodo Global Limited, operating under the brand name “Moist” (“Company,” “we,” “us,” or “our”), is committed to preventing its platform from being used for money laundering (ML), terrorist financing (TF), fraud, and other illicit activities. This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy defines the procedures and controls established to detect, prevent, and report suspicious activities.

This policy applies to all employees, officers, directors, and contractors of Dodo Global Limited. It aligns with the following UK regulations:

• Proceeds of Crime Act 2002
• Terrorism Act 2000
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)

The policy also incorporates international AML/CTF standards applicable in India and other jurisdictions where we operate. Moist facilitates the digital distribution of prepaid rewards and vouchers, which may carry financial crime exposure. We apply a rigorous, risk-based approach to mitigate such risks.

2.1 Appointment

The Company has appointed the following Money Laundering Reporting Officer (MLRO):

• Name: Ashfaq Mehmood
• Email: hi@moist.gg

2.2 Responsibilities

The MLRO is responsible for:

• Overseeing the AML/CTF program and ensuring effective implementation
• Receiving, investigating, and escalating suspicious activity reports (SARs)
• Filing reports with the UK’s National Crime Agency (NCA) as needed
• Training staff on AML/CTF obligations
• Advising management on compliance requirements
• Reviewing and updating this policy periodically

We employ a Risk-Based Approach (RBA) to AML/CTF compliance, tailoring our procedures according to the level of risk identified.

3.1 Risk Assessment

• Customer types (industry, jurisdiction)
• Nature of services and digital products
• Payment methods and funding sources
• Delivery channels and transaction frequency

3.2 Risk Mitigation

Enhanced checks and additional verifications are implemented for higher-risk customers or transaction patterns, ensuring proportional oversight.

4.1 Eligibility

Moist services are available exclusively to verified businesses registered in the United Kingdom or India that have successfully passed KYC/KYB verification.

4.2 Information Collection

a. Business Customers:

• Registered business name, number, and address
• Nature of business activity
• Ultimate beneficial owners (≥25%) and directors

b. Authorized Representatives:

• Full name, date of birth, nationality
• Residential address
• Government-issued ID

4.3 Verification Process

Verified third-party providers (e.g., KYCAid) are used for document and identity validation through public records and certified data sources.

4.4 PEPs & Sanctions Screening

All users are screened against PEP and sanctions databases (UK HMT, OFAC, EU, UN). Enhanced Due Diligence (EDD) is applied when higher risk is detected.

4.5 Ongoing Due Diligence

Accounts undergo periodic reviews and re-verification based on trigger events or changes in ownership or behavior. Anonymous or fictitious accounts are strictly prohibited.

EDD measures are applied in higher-risk scenarios such as:

• Politically Exposed Persons (PEPs)
• Customers from high-risk jurisdictions
• Complex ownership structures
• Unusual or inconsistent transaction behavior

Additional documentation, proof of funds, senior management approval, or continuous monitoring may be required.

All transactions are prepaid per our Terms of Service. We monitor activity for indicators such as:

• Unusual frequency or volume
• Connections to sanctioned countries
• Rapid movement of value or inconsistent funding

Automated tools and manual reviews flag suspicious activity for further examination and, where necessary, reporting to authorities.

Moist strictly prohibits use of its platform for illegal or high-risk activities, including:

• Illegal trade or financial crimes
• Drugs or drug-related paraphernalia
• Counterfeit or stolen goods
• Adult or escort services
• Unlicensed or fraudulent financial schemes

Violations result in immediate suspension or termination and may be reported to law enforcement.

8.1 Internal Reporting

Employees must promptly report suspicious activity to the MLRO. Internal reports are confidential.

8.2 Investigation & Escalation

The MLRO investigates and files reports with the National Crime Agency (NCA) when warranted.

8.3 Tipping Off

Disclosing (“tipping off”) a customer that they are under investigation is a criminal offense and strictly prohibited.

Records of KYC/KYB data, transaction logs, SARs, and AML training documentation are retained for at least five (5) years after account closure or termination, in accordance with legal requirements and our Privacy Policy.

All relevant employees undergo AML/CTF training during onboarding and annually thereafter. Topics include:

• AML/CTF obligations and laws
• Recognizing red flags and typologies
• CDD, EDD, and SAR procedures
• MLRO escalation and reporting

This Policy is reviewed annually or following significant changes to regulation, company structure, or risk exposure. Updates require approval from senior management and are communicated to all staff.

• MLRO: Ashfaq Mehmood
• Email: hi@moist.gg
• Company: Dodo Global Limited
• Address: 128 City Road, London, EC1V 2NX, United Kingdom