ANTI-MONEY LAUNDERING POLICY

(AML) Anti-Money Laundering Policy’s Objective: We hope to provide the best security for all users on https://www.hapabox.com. The registration process is secure, and our deposit method has not been stolen or used by others. This is an investigation into how HapaBox set up a money laundering (ML) scheme.

HapaBox has also taken reasonable measures to control and limit ML risks, such as providing appropriate means. HapaBox is committed to high standards of anti-money laundering (AML) compliance and requires management and employees to comply with these standards to prevent the use of its services for money laundering purposes.

HapaBox's AML program is designed to comply with: EU: "Directive 2015/849 of the European Parliament and of the Council of May 20, 2015 on the prevention of the use of the financial system for money laundering purposes" EU: "Regulation No. 2015/847 on Information Concomitant with the Transfer of Funds" EU: Various regulations impose sanctions or restrictions on personnel and ban certain goods and technologies, including all dual-use goods BE: "The Law of September 18, 2017 on Preventing Money Laundering and Restricting the Use of Cash.

MONEY LAUNDERING

Money laundering refers to: Converting or transferring property knowing that such property comes from criminal activities or participating in such activities, with the purpose of concealing or disguising the illegal source of the property or assisting any person involved in a crime to evade the legal consequences of that person’s actions. Conceal or disguise the true nature, source, location, disposal, movement, rights or ownership of the property, knowing that the property originated from criminal activities or participated in such activities;

Acquiring, owning or using property, knowing that the property came from criminal activities or participating in such activities at the time of receipt;

Participate in, jointly implement, attempt to implement and assist, instigate, promote and counsel the implementation of any of the actions mentioned in points (a), (b) and (c).

Even if the activity that generates the money laundered property is carried out in the territory of another member state or a third country, it shall be regarded as money laundering.

POLICY IMPLEMENTATION REQUIREMENTS

Every major change to HapaBox's anti-money laundering policy requires the approval of HapaBox's management.

Enterprise Wide Risk Assessment (EWRA)

As part of its risk-based approach, HapaBox conducted an AML "Enterprise Wide Risk Assessment" (EWRA) to identify and understand the risks specific to HapaBox and its business lines. The HapaBox’s AML risk policy is determined after identifying and recording the risks inherent in its business terms (such as the products and services provided by the website). Banks, the geographic location of the banking business, customers and transactions, and other qualitative or emerging risks.

The identification of AML risk categories is based on HapaBox's understanding of regulatory requirements, regulatory expectations and industry guidance.

EWRA will be reassessed every year.

Due Diligence

HapaBox has established standards for "Know Your Customer" ("KYC"). According to these standards, each customer with a risk-related profile must undergo Due Diligence. This involves identifying and verifying their identity, their representatives and their beneficial owners based on documents, data or information from a reliable and independent source. This also helps to assess the credibility of the information provided by HapaBox. The source complies with domestic and European anti-money laundering laws and regulations.

The first step of applying the KYC principle is to verify the customer’s identity using the required identification documents.