1. Introduction and scope of application

MyGOLD SPA (hereinafter the “Company”), operating under the trading name The Real Money, is subject to the anti-money laundering and counter-terrorist financing (AML/CFT) obligations set forth by applicable Irish and European legislation, as an entity authorised by the Central Bank of Ireland pursuant to the MiFID II Directive.

This Policy describes, in a clear and accessible manner, the procedures that THE REAL MONEY adopts to prevent the use of the Platform and the Services for illicit purposes, and the rights and obligations of the customer in this context.

This Policy describes, in a clear and accessible manner, the procedures that THE REAL MONEY adopts to prevent the use of the Platform and the Services for illicit purposes, and the rights and obligations of the customer in this context.

2. Regulatory references

3.Customer due diligence (KYC/KYB)

Before opening an Account and accessing THE REAL MONEY Services, each customer is subject to the customer due diligence (CDD) procedure, which is mandatory under the applicable AML regulations.

3.1 KYC for Individuals

For individuals, the KYC procedure requires:

1. a) Valid identity document (identity card, passport or driving licence).
2. b) Proof of address (e.g. utility bill, bank statement, official document with address) no older than 3 months.
3. c) Tax code or equivalent in the country of residence.
4. d) Customer photograph in “selfie with document” format for biometric verification, performed via the Platform’s automated verification system.
5. e) Declaration on the source of funds, for transactions exceeding certain thresholds or for the activation of specific Services.

3.2 KYB for legal entities

For legal entities (companies, entities, associations), the KYB procedure requires:

1. a) Chamber of Commerce certificate or equivalent document certifying the legal existence and representative powers.
2. b) Articles of Association or articles of incorporation.
3. c) Identification and verification of all beneficial owners (UBOs) with a direct or indirect shareholding equal to or greater than 25%.
4. d) Full KYC for each UBO and for the legal representative acting on behalf of the company.
5. e) Documentation on the nature of the activity carried out and the source of the funds.

3.3 Enhanced Due Diligence (EDD)

In the presence of high-risk factors, THE REAL MONEY applies enhanced due diligence measures (EDD). Factors that may trigger the application of the EDD include, but are not limited to:

• Client resident or operating in high-risk countries according to the FATF, EU or CBI lists.
• Transactions of a particularly large amount or unusual structure.
• Discrepancies between the declared profile and the operations actually carried out.
• Presence of reports or alerts deriving from automated monitoring systems.

In the event of an EDD, the Company may request additional documentation, including tax returns, recent pay stubs, bank statements, contracts, or other documents certifying the source of the funds. Refusal to provide such documentation will result in the request being denied or the Account being suspended.

3.4 Identification of the beneficial owner (UBO)

In accordance with applicable anti-money laundering legislation, the Company identifies the Beneficial Owner according to the following criteria:

• For legal entities: the natural person who directly or indirectly owns or controls more than 25% of the capital or voting rights, or who exercises management control. In the absence of such identifiable persons, the legal representative or senior management.
• For trusts and similar legal entities: the settlor , the trustee, the protector (if any ) , and the beneficiaries or class of beneficiaries.

For each identified Beneficial Owner, the Company obtains a declaration signed by the legal representative, verifies the identity using the same criteria as for natural persons, and performs screening against PEP and international sanctions lists.

In the absence of sufficient information to identify the Beneficial Owner, the Company will not proceed with the activation of the commercial relationship.

3.5 Absolute prohibition of anonymous relationships

The Company does not establish or maintain business relationships with anonymous customers, those with fictitious identities, those who refuse to provide the information necessary for verification, or who provide false or contradictory information.

If it is impossible to complete the customer verification, TOGO INFINITY Limited will refuse to establish a relationship, will not execute transactions, and will assess whether there are grounds for filing a suspicious transaction report with the competent authorities, including the Financial Intelligence Unit Ireland, in accordance with applicable legislation.

4. Continuous monitoring of operations

The Company continuously monitors the transactions carried out through the Platform in order to promptly identify anomalous behavior or behavior potentially connected to illegal activities.

4.1 Periodic profile updates

THE REAL MONEY reserves the right to request that customers update their data and documentation at any time, particularly when significant changes occur in their transactions or their profile. Customers are required to respond promptly to such requests.

5. Reporting obligations to the Authorities

The Company is required to report to the competent authorities without undue delay when it knows, suspects or has reasonable grounds to suspect that the funds involved are of illicit origin or connected to the financing of terrorism.

REPORTING OBLIGATION — Once a suspicious transaction report ( Suspicious Transaction Report (STR), it is prohibited by law to inform the customer of the report made. This prohibition is set forth by Irish and European AML regulations and applies except where expressly permitted by law.

5.1 Competent authorities

6. Customer obligations and rights

6.1 Customer obligations

The Company’s customer is required to:

• Provide true, accurate and up-to-date information during registration and at every stage of the contractual relationship.
• Submit the required documentation as part of the KYC/KYB procedures within the indicated timeframes.
• Promptly communicate any significant changes to your data (residence, nationality, nature of business, corporate structure for legal entities).
• Do not use the Platform or the Services for the purposes of money laundering, terrorist financing or any other illegal activity.
• Do not provide false or misleading information in order to evade verification procedures.

6.2 Consequences of failure to comply

Failure to comply with the obligations set out in paragraph 6.1 may result in:

• Rejection of the request to open an Account or activate one or more Services.
• Rejection of the request to open an Account or activate one or more Services.
• Reporting to the competent authorities, where the customer’s conduct constitutes suspicious transactions pursuant to AML regulations.

MyGOLD SpA is not required to provide detailed reasons in cases where this is prohibited or limited by applicable AML regulations or by provisions of the competent Authorities.

6.3 Customer rights

The customer has the right to:

• Be informed, clearly and in advance, about the verification procedures to which you will be subjected and about the documents that may be requested.
• Receive a reasoned response in the event of rejection of the request to open an Account, except in cases where communication is prohibited by AML regulations (e.g. in the presence of a suspicious transaction report).
• Exercise your rights regarding the protection of personal data (access, rectification, erasure, portability) in accordance with the GDPR legislation and the Privacy Policy published on the website ( LINK ), within the limits permitted by the AML legislation regarding data retention.

7. Data retention and documentation

The Company retains all documentation collected as part of AML/KYC/KYB procedures for a minimum period of 5 years from the termination of the contractual relationship with the customer, in compliance with Irish legislation ( Criminal Justice (Money Laundering and Terrorist Financing) Act 2010-2021) and applicable European legislation.

In the event of suspicious transactions reported to the Authorities, the documentation is retained for a minimum period of 5 years from the date of the report, or for any longer period required by the competent Authority.

The data collected for AML purposes is stored and used exclusively for regulatory compliance purposes and is not used for commercial or profiling purposes.

8. Training and internal governance

8.1 AML/Compliance Officer

THE REAL MONEY has appointed an AML/Compliance Officer responsible for:

• Oversee the implementation of this AML Policy and regulatory updates.
• Receive internal reports of suspicious transactions and assess any obligation to report them to the Authorities
• Manage relationships with the Central Bank of Ireland and the Financial Intelligence Unit on AML matters.
• Ensure mandatory periodic training of staff and collaborators.

8.2 Mandatory training

All employees, contractors, and Company members receive mandatory AML/CFT training upon commencement of employment and at least annually. The training includes:

• Current Irish and European AML regulations and relevant updates
• Internal KYC/KYB procedures and due diligence
• Recognition of anomaly indicators and suspicious transactions.
• Internal reporting procedure to the AML/Compliance Manager.
• Specific obligations regarding advisory services (MiFID II).

8.3 Periodic review

This Policy is subject to review at least annually, or in the event of significant regulatory changes, by the AML/Compliance Officer with the approval of the Board of Directors. The updated version is always available on the Platform.

9. Summary: what we ask the customer and why

To make the process as clear as possible, here is a summary of what the Company may request and the regulatory reason for each request:

THE REAL MONEY — TOGO INFINITYLIMITED — Block 4 Harcourt Centre, Harcourt Road, Dublin 2, Ireland, D02 HW77