Anti-Money Laundering & Counter-Terrorist Financing Statement

1. Purpose and commitment

Properation Consultant Limited OÜ (registry code 17176878), a private limited company registered in the Republic of Estonia, is committed to conducting business lawfully and transparently. This Statement describes the measures we apply to prevent our services and payment flows from being used for money laundering, terrorist financing, sanctions evasion, fraud, or other financial crime.

We do not tolerate the use of our company, services, or bank accounts for any unlawful purpose.

2. Nature of our business and regulatory status

Properation Consultant Limited OÜ provides business-to-business technology services: cloud software development, data analytics and reporting systems, automation and system integration, and dedicated development teams. Our registered principal activity is computer programming (EMTAK 62101), and we are registered for VAT in Estonia (EE102832626).

Properation Consultant Limited OÜ is not a credit institution, financial institution, payment service provider, or virtual asset service provider, and does not hold or manage funds on behalf of others. We therefore:

• do not provide payment, remittance, money-transfer, currency-exchange, or escrow services;
• do not provide cryptocurrency or virtual-asset custody, exchange, or wallet services;
• do not receive or forward funds on behalf of third parties that are unrelated to our own service contracts;
• do not accept cash or anonymous payments, or payments that cannot be linked to a contracting client and a specific invoice.

Although our business is not a financial service, we apply the risk-based principles of the Estonian Money Laundering and Terrorist Financing Prevention Act (Rahapesu ja terrorismi rahastamise tõkestamise seadus), the applicable EU anti-money-laundering framework, and EU, UN, and other applicable international sanctions as part of our own risk management, and we cooperate fully with our banks and payment providers in their due-diligence obligations.

3. Our business model

For transparency, our commercial model is as follows:

• Clients — business customers in various countries — contract with Properation Consultant Limited OÜ under a service agreement and Statement of Work, and pay Properation Consultant Limited OÜ's invoices for the agreed scope.
• Development partner — an established software development company in Taiwan performs development work under a written development agreement with Properation Consultant Limited OÜ, aligned back-to-back with our client commitments, and is paid by Properation Consultant Limited OÜ monthly for the man-days actually provided, supported by timesheets and reviewed deliverables.
• Properation Consultant Limited OÜ is responsible to the client for delivery, and its margin reflects project management, quality assurance, and contractual responsibility.

Every incoming and outgoing payment relates to a specific written contract, Statement of Work, and invoice.

4. Client due diligence (Know Your Business)

Before entering into a contract, and on an ongoing basis during the relationship, we carry out due diligence on clients proportionate to the risk. This includes:

1. Identification of the legal entity — company name, registration number, jurisdiction, registered address, and a certificate of incorporation or registry extract.
2. Beneficial ownership — identification of the natural persons who ultimately own or control the client (in general, more than 25% ownership or control), and of the persons authorised to sign.
3. Sanctions and PEP screening — screening of the client, its directors, and beneficial owners against EU, UN, UK, and US (OFAC) sanctions lists and for politically exposed persons.
4. Purpose of the relationship — understanding the client's business, the nature and intended use of the software or services to be delivered, the markets in which the client operates, and why the client is engaging us.
5. Licences and permissions — where the client's business or the intended use of the deliverables is subject to licensing or regulatory approval in a market where it operates, evidence that the client holds the required licences.
6. Source of funds — understanding where the funds used to pay us come from, and that they relate to the client's legitimate business.

Where information is incomplete, inconsistent, or indicates higher risk, we request further documentation, apply enhanced checks, or decline the engagement.

5. Development partner due diligence

Development partners are subject to equivalent checks before we engage them and before payments are released:

• verification of company registration, ownership, and authorised signatories;
• sanctions screening of the company and its beneficial owners;
• a written subcontract covering the scope of work, pricing, confidentiality, and assignment of intellectual property;
• payment only to a bank account held in the partner company's own name, against an invoice supported by timesheets and deliverables that we have reviewed.

6. Prohibited clients and activities

Properation Consultant Limited OÜ will not enter into or continue a business relationship with:

• persons or entities subject to EU, UN, UK, or US sanctions, or owned or controlled by them;
• clients established in, or projects intended for, jurisdictions subject to comprehensive sanctions or identified by the FATF as high-risk jurisdictions subject to a call for action;
• shell companies without verifiable business activity, or clients that refuse to identify their beneficial owners;
• projects intended to facilitate illegal activity, including unlicensed gambling, fraud, unlicensed financial services, malware, or circumvention of sanctions or export controls;
• projects whose intended use is unlawful in a market where the client operates, or that require licences the client does not hold;
• content that is illegal, including content that sexually exploits minors, promotes terrorism, or infringes the intellectual-property rights of others.

7. Payment and invoicing controls

• Payments are received through regulated financial institutions.
• Every payment must be traceable to the contracting client and to a specific invoice. Payments whose origin cannot be established are not accepted and are returned.
• Every invoice refers to a signed contract or Statement of Work and a defined milestone, period, or deliverable.
• Overpayments are refunded only to the originating account.
• Contracts, invoices, acceptance records, and due-diligence records are retained in accordance with Estonian accounting and legal retention requirements.

8. Monitoring, reporting, and cooperation

We monitor our business relationships for unusual activity, such as payments inconsistent with the contract, requests to pay or receive funds via third parties, or unexplained changes in ownership.

Where we identify activity that may indicate money laundering, terrorist financing, or sanctions violations, we may suspend work, decline or return payments, and terminate the relationship. Where required or permitted by law, we report to the Estonian Financial Intelligence Unit (Rahapesu Andmebüroo) or other competent authorities.

We cooperate with our banks, payment institutions, auditors, and authorities, and provide information about our business, contracts, and counterparties on lawful request.

9. Responsibility and review

Responsibility for this Statement and for its implementation lies with the Management Board of Properation Consultant Limited OÜ. The Statement is reviewed at least once a year and whenever our business model or the applicable law changes.

10. Contact

Questions about this Statement, and due-diligence requests from banks, payment institutions, or business partners, may be sent to:

Properation Consultant Limited OÜ — Compliance
Vesivärava tn 50-301, Kesklinna linnaosa, 10152 Tallinn, Harju maakond, Estonia
Email: [email protected]