Anti-Money Laundering and Counter-Terrorist Financing Policy

1. Introduction

This Anti-Money Laundering and Counter-Terrorist Financing Policy (the "Policy") sets out the principles and controls adopted in connection with the services offered under the Pipcy brand through pipcy.com (the "Website") and related platforms and systems.

The purpose of this Policy is to describe the measures implemented to prevent the Website and Services from being used for money laundering, terrorist financing, sanctions evasion, fraud, or other unlawful activity.

This Policy should be read together with our Terms of Service, Privacy Policy, and any related compliance procedures applied by us from time to time.

2. Our Business Model

The services offered under the Pipcy brand are provided by Conquest Services Limited, a company incorporated in the United Arab Emirates ("Conquest", "Company", "we", "us", or "our").

Pipcy offers evaluation services through simulated trading challenges conducted in a simulated environment using fictitious funds only.

For the avoidance of doubt:

• no live trading is carried out on behalf of customers;
• no customer funds are accepted as trading deposits;
• no customer assets are held for investment or custody purposes;
• no brokerage or investment services are provided; and
• all fees paid by customers constitute consideration for evaluation services only.

In providing the Services, Conquest uses certain service providers and operational partners, including:

• Pipcy Ltd., which provides MT5-related technical infrastructure and access to the simulated trading environment; and
• Rogano Limited, which provides software, back-office, marketing, payment collection and settlement, and related operational services to Conquest.

3. Compliance Approach

Although the Services are not brokerage or custody services, we take a risk-based approach to anti-money laundering (AML), counter-terrorist financing (CTF), sanctions compliance, fraud prevention, and related financial crime controls.

We reserve the right to apply compliance and verification measures where we consider it necessary or appropriate, including before, during, or after the provision of the Services.

Our compliance approach may include, without limitation:

• customer identification and verification;
• sanctions and adverse media screening;
• fraud prevention and risk checks;
• payment source and transaction monitoring;
• behavioural and technical monitoring;
• account review and escalation procedures; and
• cooperation with competent authorities where required.

4. Risk-Based Controls

We apply controls proportionate to the nature of the Services, the payment methods used, the jurisdictions involved, user behaviour, and the risk indicators identified during onboarding or ongoing monitoring.

Risk factors that may lead to enhanced review include, without limitation:

• high-risk or sanctioned jurisdictions;
• inconsistencies in personal or payment information;
• use of proxies, VPNs, anonymisation tools, or suspicious device patterns;
• unusual transaction or payment behaviour;
• abusive chargeback or refund activity;
• attempts to evade identity checks or compliance requests;
• links to fraud, illegal activity, or sanctions exposure; and
• any other circumstances that raise reasonable concerns regarding misuse of the Website or Services.

5. Customer Identification and Verification

We may require customers to complete identity verification (KYC) and provide supporting information or documentation at any stage of the relationship, including prior to granting access to certain features, before processing any reward or payout-related request, when reviewing suspicious activity, or when otherwise required for compliance, fraud prevention, or operational purposes.

Verification may include, without limitation:

• full legal name;
• date of birth;
• residential address;
• email address and phone number;
• government-issued identification documents;
• proof of address;
• liveness or biometric verification;
• source of funds or payment source information where appropriate; and
• any additional information or documentation reasonably required by us or by our service providers.

Identity and compliance checks may be carried out by us directly or through duly appointed third-party providers acting on our behalf or in their own independent legal capacity.

6. Payment Monitoring and Financial Crime Controls

Payments for the Services may be processed through third-party service providers, including providers engaged by Conquest for payment collection and settlement purposes.

We may review payment and transaction data to detect suspicious activity, fraud, sanctions exposure, misuse of payment instruments, or other unlawful conduct.

We reserve the right to:

• delay or refuse the provision of Services pending review;
• reject a payment or order;
• request additional information or verification;
• suspend or restrict access to an account;
• cancel access to a challenge or service;
• refuse any reward, withdrawal, reimbursement, refund, or payout-related action pending satisfactory compliance review; and
• report or disclose information where required by law or where necessary to protect our rights, users, systems, or business.

7. Sanctions Compliance

We do not offer the Services in jurisdictions or to persons where doing so would be unlawful or would expose us or our service providers to sanctions, AML, CTF, export control, or similar compliance risk.

We reserve the right to screen customers, counterparties, transactions, devices, and related activity against sanctions lists, embargoes, and other legal or regulatory restrictions.

If we determine, or reasonably suspect, that a person, payment, or activity may be subject to sanctions restrictions or other legal prohibitions, we may refuse, suspend, restrict, or terminate access to the Services without liability.

8. Prohibited Conduct

The Website and Services must not be used for or in connection with:

• money laundering;
• terrorist financing;
• fraud or payment abuse;
• sanctions evasion;
• identity theft or impersonation;
• unlawful chargeback behaviour;
• use of stolen or unauthorised payment instruments;
• concealment of beneficial ownership or source of funds where relevant;
• deceptive, abusive, or unlawful activity; or
• any conduct that may expose us, our users, or our providers to legal, regulatory, reputational, operational, or financial risk.

9. Ongoing Monitoring

We may monitor accounts, transactions, device signals, usage behaviour, and technical activity on an ongoing basis for compliance, fraud prevention, and security purposes.

Monitoring may be manual, automated, or both, and may involve internal reviews, vendor tools, risk scoring, anomaly detection, or escalation procedures.

10. Requests for Information

We may request additional information, explanations, or documentation from a customer where reasonably necessary for compliance, fraud prevention, security, payment review, sanctions screening, or related purposes.

Failure to provide requested information within the required timeframe, or the provision of false, misleading, incomplete, or inconsistent information, may result in suspension, restriction, cancellation, or termination of the Services.

11. Reporting and Cooperation

We reserve the right to cooperate with regulators, law enforcement agencies, payment institutions, financial institutions, fraud prevention bodies, and other competent authorities where required or appropriate.

Where required by law, or where we reasonably consider it necessary to protect our rights, systems, users, or business, we may disclose relevant information and take any action considered appropriate in the circumstances.

12. Data Processing and Recordkeeping

Personal data processed in connection with this Policy shall be handled in accordance with our Privacy Policy and applicable law.

We may retain compliance, verification, screening, payment, transaction, and monitoring records for as long as reasonably necessary to comply with legal obligations, manage risk, prevent fraud, resolve disputes, and establish, exercise, or defend legal claims.

13. No Guarantee of Access

Completion of any verification or compliance review does not create any obligation on our part to provide or continue providing the Services.

We reserve the right, in our sole discretion and subject to applicable law, to refuse, suspend, restrict, or terminate access to the Website or Services where compliance, fraud, security, legal, or operational concerns arise.

14. Changes to This Policy

We may amend or update this Policy from time to time. Any updated version will be made available on the Website and will become effective upon publication unless stated otherwise.

15. Contact

If you have any questions about this Policy, please contact us at:

Conquest Services Limited, Office No. 416, Burlington Tower, Business Bay, P.O. Box 487644, Dubai, United Arab Emirates

[email protected]