KYC Policy of Aquila Ltd.

The Company adheres to and complies with “Know your customer” principles, which aim to prevent financial crime and money laundering through client identification and due diligence.

The Company reserves the right, at any time, to ask for any KYC documentation it deems necessary to determine the identity and location of a user in 998join.com. We reserve the right to restrict the service, payment, or withdrawal until identity is sufficiently determined, or for any other reason in our sole discretion based on the legal framework.

We take a risk-based approach and perform strict due diligence checks and ongoing monitoring of all clients, customers, and transactions. As per the money laundering regulations, we utilize three stages of due diligence checks, depending on the risk, transaction, and customer type.

• SDD — simplified due diligence is used in instances of extremely low-risk transactions that do not meet the required thresholds
• CDD — customer due diligence is the standard for due diligence checks, used in most cases for verification and identification
• EDD — Enhanced Due Diligence is used for high-risk customers, large transactions or special cases.

Separately and in addition to the above, when a user makes an aggregate lifetime total of deposits exceeding EUR 5,000 or requests a withdrawal of any amount inside the 998join.com, or attempts to or completes a transaction that is deemed suspicious, then it is compulsory for them to complete the full KYC process.

During this process, the user will have to input some basic details about themselves and then upload:

• A copy of Government Issued Photo ID (in some cases front and back depending on the ID document)
• A selfie of themselves holding the ID doc
• A bank statement/Utility Bill