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ANTI-MONEY LAUNDERING (AML) POLICY​​

1. POLICY STATEMENT

Gamezon Space Corporation (“Gamezon”, “Company”, or “Corporation”), a multinational e-commerce, fintech, logistics, and technology enterprise headquartered in Nairobi, is fully committed to preventing money laundering, terrorist financing, fraud, corruption, sanctions violations, and other financial crimes across all its global operations, platforms, investment activities, payment systems, shareholder services, and digital financial ecosystems.

This Anti-Money Laundering (“AML”) Policy establishes the Company’s framework for:

  • Detecting and preventing financial crime; 

  • Monitoring suspicious activities;

  • Conducting investor and customer verification;

  • Ensuring compliance with applicable AML laws and regulations;

  • Protecting shareholders, investors, customers, employees, and stakeholders from financial abuse.

The Company adopts a zero-tolerance approach toward money laundering, terrorism financing, fraud, bribery, corruption, illicit financial flows, and any misuse of its systems or services.

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2. PURPOSE OF THE POLICY

The purpose of this AML Policy is to:

  • Establish AML compliance standards;

  • Prevent the Company from being used for illicit financial activities;

  • Ensure proper customer and investor due diligence;

  • Identify and report suspicious transactions;

  • Protect the integrity of the Company’s financial systems;

  • Comply with local and international AML regulations;

  • Support transparency in shareholder and investment operations.

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3. SCOPE OF APPLICATION

This Policy applies to:

  • Directors

  • Shareholders

  • Employees

  • Contractors

  • Investors

  • Consultants

  • Vendors

  • Payment partners

  • Financial institutions

  • Third-party service providers

  • Platform users

  • Agents and representatives

The Policy covers all operations conducted by or on behalf of the Company globally.

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4. LEGAL & REGULATORY COMPLIANCE

The Company shall comply with all applicable anti-money laundering and counter-terrorism financing laws, including regulations issued by:

  • Financial Action Task Force (FATF)

  • Central Bank of Kenya

  • Financial Reporting Centre

  • United Nations sanctions frameworks

  • Applicable securities and financial regulatory authorities

  • International sanctions and financial crime prevention regulations

The Company shall also comply with:

  • Know Your Customer (KYC) regulations

  • Counter-Terrorist Financing (CTF) laws

  • Economic sanctions laws

  • Data protection and privacy laws

  • Anti-bribery and anti-corruption laws

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5. AML COMPLIANCE FRAMEWORK

The Company shall maintain a risk-based AML compliance program consisting of:

  • Customer due diligence procedures;

  • Investor verification systems;

  • Transaction monitoring controls;

  • Sanctions screening;

  • Recordkeeping standards;

  • Internal reporting mechanisms;

  • Employee training;

  • Compliance oversight;

  • Independent audits and reviews.

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6. RISK-BASED APPROACH

The Company adopts a risk-based approach to identify, assess, and mitigate money laundering and terrorist financing risks.

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6.1 Risk Assessment Categories

Risk assessments shall consider:

A. Customer Risk

  • Politically Exposed Persons (PEPs)

  • High-net-worth individuals

  • Anonymous or shell entities

  • Offshore entities

  • High-risk industries

B. Geographic Risk

  • High-risk jurisdictions

  • Sanctioned countries

  • Countries with weak AML controls

C. Transaction Risk

  • Large cash movements

  • Unusual transaction patterns

  • Complex ownership structures

  • Rapid movement of funds

D. Product & Service Risk

  • Digital payments

  • Investment platforms

  • Shareholder services

  • Cross-border transactions

  • Cryptocurrency exposure

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6.2 Enhanced Due Diligence (EDD)

Enhanced Due Diligence shall be conducted for high-risk individuals or entities, including:

  • Politically exposed persons;

  • High-value investors;

  • Cross-border financial activities;

  • Complex ownership structures;

  • High-risk jurisdictions.

EDD measures may include:

  • Source of funds verification;

  • Source of wealth verification;

  • Senior management approval;

  • Enhanced monitoring;

  • Independent background checks.

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7. KNOW YOUR CUSTOMER (KYC) & INVESTOR VERIFICATION

The Company shall implement robust customer and investor verification systems.

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7.1 Identity Verification Requirements

Before onboarding customers, investors, shareholders, or business partners, the Company may require:

Individuals

  • Government-issued identification;

  • Passport;

  • National ID card;

  • Proof of address;

  • Tax identification number;

  • Selfie or biometric verification.

Corporate Entities

  • Certificate of incorporation;

  • Business registration documents;

  • Tax certificates;

  • Beneficial ownership details;

  • Director information;

  • Corporate structure documentation.

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7.2 Beneficial Ownership Verification

The Company shall identify and verify ultimate beneficial owners (UBOs) of corporate entities and investment vehicles.

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7.3 Ongoing Monitoring

The Company shall continuously monitor customer and investor relationships to ensure:

  • Consistency with known risk profiles;

  • Detection of unusual behavior;

  • Compliance with regulatory obligations.

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8. SUSPICIOUS TRANSACTION MONITORING

The Company shall maintain systems to detect suspicious, unusual, or potentially unlawful financial activity.

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8.1 Indicators of Suspicious Activity

Suspicious activities may include:

  • Unusual transaction volumes;

  • Structuring transactions to avoid reporting thresholds;

  • Rapid movement of funds;

  • Inconsistent investor information;

  • Use of multiple accounts without justification;

  • Transactions involving sanctioned entities;

  • Unexplained wealth;

  • Abnormal payment patterns;

  • Fake documentation;

  • Attempts to conceal ownership.

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8.2 Monitoring Systems

The Company may implement:

  • Automated transaction monitoring tools;

  • AI-driven fraud detection systems;

  • Behavioral analytics;

  • Risk scoring mechanisms;

  • Sanctions screening databases;

  • Real-time compliance alerts.

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8.3 Internal Escalation

Employees must immediately escalate suspicious activities to the AML Compliance Officer or designated compliance team.

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9. REPORTING OBLIGATIONS

The Company shall comply with all legal reporting obligations relating to suspicious transactions and financial crimes.

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9.1 Suspicious Transaction Reports (STRs)

Where required by law, the Company shall file Suspicious Transaction Reports (STRs) or Suspicious Activity Reports (SARs) with appropriate regulatory authorities.

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9.2 Regulatory Cooperation

The Company shall cooperate with:

  • Financial intelligence units;

  • Law enforcement agencies;

  • Regulatory authorities;

  • Courts and government investigators

where legally required.

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9.3 Confidentiality of Reports

Employees and stakeholders are prohibited from disclosing (“tipping off”) that a suspicious activity report has been filed.

Unauthorized disclosure may result in disciplinary action or legal consequences.

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10. SANCTIONS SCREENING

The Company shall screen customers, investors, shareholders, vendors, and transactions against:

  • International sanctions lists;

  • Terrorism watchlists;

  • Politically exposed persons databases;

  • Adverse media databases.

The Company reserves the right to reject, suspend, freeze, or terminate relationships involving sanctioned or prohibited individuals or entities.

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11. RECORDKEEPING REQUIREMENTS

The Company shall maintain accurate records relating to:

  • Customer identification;

  • Investor verification;

  • Transaction history;

  • Risk assessments;

  • Compliance investigations;

  • Regulatory reports.

Records shall be retained for a minimum period required by applicable law.

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12. EMPLOYEE TRAINING & AWARENESS

The Company shall provide AML training programs to relevant personnel covering:

  • AML laws and regulations;

  • Suspicious activity indicators;

  • Reporting procedures;

  • Data protection obligations;

  • Investor verification procedures;

  • Fraud prevention mechanisms.

Training shall be conducted periodically and documented.

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13. INTERNAL CONTROLS & COMPLIANCE PROCEDURES

The Company shall establish internal controls including:

  • Segregation of duties;

  • Approval workflows;

  • Risk-based monitoring;

  • Independent compliance reviews;

  • Audit trails;

  • Access control systems.

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14. AML COMPLIANCE OFFICER

The Company shall designate an AML Compliance Officer responsible for:

  • Implementing AML controls;

  • Monitoring compliance;

  • Filing regulatory reports;

  • Conducting investigations;

  • Managing AML training;

  • Liaising with regulators.

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15. AUDITS & POLICY REVIEW

The Company shall conduct periodic AML audits and reviews to:

  • Assess effectiveness of controls;

  • Identify compliance gaps;

  • Improve risk mitigation measures;

  • Ensure regulatory alignment.

This Policy shall be reviewed annually or whenever required by law or operational changes.

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16. BREACHES & DISCIPLINARY ACTIONS

Failure to comply with this Policy may result in:

  • Account suspension;

  • Termination of employment or business relationships;

  • Regulatory reporting;

  • Financial penalties;

  • Civil liability;

  • Criminal prosecution.

The Company reserves the right to freeze or reject transactions suspected of involving unlawful activities.

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17. DATA PROTECTION & CONFIDENTIALITY

All AML investigations and compliance activities shall be conducted confidentially and in accordance with applicable data protection laws.

Sensitive information shall only be accessed by authorized personnel.

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18. WHISTLEBLOWER PROTECTION

Employees and stakeholders are encouraged to report suspicious or unethical activities in good faith.

The Company prohibits retaliation against whistleblowers who report concerns honestly and lawfully.

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19. GOVERNING LAW

This Policy shall be governed by the laws of:

the Republic of  Kenya

and applicable international financial crime prevention regulations.

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20. POLICY APPROVAL

Approved by:

Gamezon Space Corporation

Authorized By: Wycliffe Wejuli
Title: The Company President
Date: 1st May, 2026

Signature: __________________

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OPTIONAL ADVANCED AML CONTROLS

The Company may additionally implement:

  • AI-powered AML surveillance systems

  • Blockchain transaction monitoring

  • Cryptocurrency wallet screening

  • Real-time sanctions intelligence

  • Automated fraud scoring systems

  • Cross-border payment risk controls

  • Continuous investor due diligence

  • ESG financial crime monitoring

  • Cyber-fraud intelligence integration

  • Biometric identity verification

  • Anti-bribery and anti-corruption controls

  • Global tax compliance integration

  • Transaction velocity monitoring

  • Multi-factor investor authentication

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