Anti-Money Laundering & Counter-Terrorist Financing Policy

1. Purpose

This policy states how Gigaverse AI, Inc. ("Gigaverse") prevents its products from being used to launder money, finance terrorism, evade sanctions, or commit fraud, and how it cooperates with the regulated financial institutions that carry legal AML obligations on the transactions it facilitates.

2. What Gigaverse is, and is not

• Gigaverse is a Delaware software company. It is not a bank, money services business, broker-dealer, or money transmitter, and it does not hold, pool, or custody customer funds.
• The only payments Gigaverse itself collects are its own subscription fees (Pro and Wealth Builder plans), by card, Apple Pay, or Google Pay, through a third-party processor, Coinflow Technologies, Inc. Those fees settle to Gigaverse's operating account. They are never deposited into any customer account.
• Retirement and brokerage accounts offered through Gigaverse are opened and held at a FINRA/SIPC-member broker-dealer, which is the regulated financial institution responsible for the Customer Identification Program (CIP), Customer Due Diligence, sanctions screening, transaction monitoring, and Suspicious Activity Reporting on those accounts.
• Bank connections are read-only and provided through Plaid; Gigaverse cannot move money out of a linked bank account.
• Gigaverse is pursuing registration as an investment adviser with the SEC and is not currently registered.

3. Scope

This policy applies to all Gigaverse personnel and contractors, to every payment Gigaverse accepts, to every account-opening flow Gigaverse initiates with a partner institution, and to the partner and referral programs described in the Referral Program Terms.

4. Governance

• Compliance Officer. The Chief Executive Officer serves as AML Compliance Officer until a dedicated officer is appointed, and is responsible for this policy, training, escalations, and regulator or partner inquiries. Contact: [email protected].
• Board oversight. The Board reviews this policy, material incidents, and partner findings at least annually.
• Training. Every person with access to customer or payment data completes AML/CTF and sanctions training within 30 days of joining and annually thereafter; completion is recorded.
• Independent review. The program is reviewed at least annually by a person independent of its day-to-day operation, or by an external reviewer.

5. Customer identification and due diligence

• No anonymous accounts. Every Gigaverse account requires a verified email and, before any account can be opened at a partner institution, government-ID identity verification through the partner's CIP or Plaid Identity Verification. Gigaverse does not open accounts for customers who cannot be identified.
• Payer identity. Subscription payments are screened by Coinflow, which performs its own identity, sanctions, and fraud checks on the payer and may decline a payment. Gigaverse does not accept cash, money orders, cryptocurrency from customers, or payment from one person on behalf of another.
• Eligibility. Customers must be at least 18 and U.S. persons with a valid Social Security or taxpayer identification number to open a retirement account. Gigaverse does not serve residents of comprehensively sanctioned jurisdictions.
• Enhanced due diligence. Gigaverse escalates to the partner institution, and may decline or close an account, where a customer is a politically exposed person, is flagged by a sanctions screen, provides inconsistent identity information, or where activity is inconsistent with a retail retirement-savings profile.

6. Sanctions

Gigaverse relies on its partner institutions' screening against the U.S. Treasury Office of Foreign Assets Control (OFAC) Specially Designated Nationals list and other applicable lists at onboarding and on an ongoing basis. Gigaverse independently blocks sign-ups and payments from IP ranges associated with comprehensively sanctioned jurisdictions, refuses business with any person or entity it knows to be sanctioned, and will freeze access and notify the relevant partner immediately on a confirmed match.

7. Monitoring and red flags

Because Gigaverse does not move customer money, its monitoring is focused on the signals it can see. The following are escalated to the Compliance Officer within one business day:

• Multiple accounts created with the same identity documents, device, or payment card; or a card in a name that does not match the account holder
• Repeated failed identity verification followed by new attempts with altered details
• Subscription payments that are rapidly charged, refunded, and re-charged, or chargeback patterns consistent with card testing
• A customer's request to route retirement contributions, refunds, or payouts to a third party
• Any request to accept payment for a retirement contribution by card (Gigaverse does not do this) or to move funds outside the partner institution's rails
• Notification from Coinflow, Plaid, or the broker-dealer of a sanctions hit, fraud finding, or suspicious activity

8. Escalation and reporting

• Personnel report concerns to [email protected]; reports may be made anonymously and retaliation is prohibited.
• The Compliance Officer reviews each report, documents the decision, and where warranted refers the matter to the partner institution that holds the relevant regulatory reporting obligation (for example, the broker-dealer's SAR process or Coinflow's fraud team), and to law enforcement where required.
• Gigaverse does not tip off a customer that a report or referral has been made.
• Gigaverse responds to lawful requests from regulators, law enforcement, and partner institutions and preserves relevant records on request.

9. Refunds and chargebacks

Refunds are returned only to the original payment method and never to a different card, bank account, or person. Refund requests that would move value to a third party are refused and escalated.

10. Partner and affiliate programs

Partners and affiliates are compensated only by revenue share on paid subscriptions or flat licence fees, never by reference to deposits, account openings, or assets, which removes the incentive to onboard customers who should not be onboarded. Partners are identified before payment and are subject to the same sanctions and red-flag rules as customers.

11. Record keeping

Identity-verification results, payment records, escalations, decisions, training records, and partner correspondence are retained for at least five years after the account closes or the transaction completes, consistent with the Data Retention and Disposal Policy, and longer where a partner, regulator, or litigation hold requires it.

12. Review

This policy is reviewed at least annually and whenever Gigaverse adds a payment method, partner institution, product, or market. Material changes are approved by the Board and posted here with a new version number.