Guo Wengui / Miles Guo — criminal case · ECF #208-2

Himalaya Coin & Himalaya Dollar.

Here at Himalaya Exchange, we are committed to protect our customers and crypto community.

Himalaya Exchange aims to set the crypto industry standard for Know Your Customers.

Our compliance teams are located in United Kingdom and Australia and provide compliance services to the group.

Most of our compliance team members have more than 5 years compliance experience in leading international banks and crypto companies.

- Auto Approval, Auto Rejection and Manual Risk Review

HIMALAYA EXCHANGE. Customer Registration Process (Individual)

- Residence and citizenship.

- Security Questions add an extra layer of customer protection to the authentication process.

- Send One Time Password (OTP) to both registered email address and phone number to authorise the account creation

- AI verification on the customer's identity and biometric information (facial recognition). - customer to provide customer profiles. Provides the basis for initial Financial Crime Risk Rating. - Risk Based Approach for further verification e.g. bank statements / SoW / SoF. Customer Registration Process (Corporate)

- Appointed Representative registers an account with email address, password. - Same registration process as Individual including Security Questions setup.

- Based on the result of the Business Risk Analysis, Himalaya Exchange only accepts the following legal entities:

- Due Diligence is conducted on the corporate entity. - Key documents to verify the ultimate ownership structure and legal status like:

- Organisation Chart, etc .

- Every Corporate customers undergoes EDD regardless of their initial Financial Crime Risk Rating. - In addition to the main party (the legal entity), the connected parties have to go through complete KYC process and provide POA. For example, UBO with 10% or above ownership, Directors, Authorised Representative. For Trust - Settlor, Protector, Beneficiary, etc. - For merchant account, an extra duediligence process will be adopted due to the high risk nature. Identification and Verification (ID&V) , Screening

- Identification and Verification. Customer provides name, address and relevant data from our secured online portal. Customer's identity is verified against the government issued ID card. AI powered facial recognition is used to ensure the picture in ID matches selfie picture. - Proof of Address. Customer address is manually verified against the bank statement, government ID, and utility bills - Name Screening is performed against PEP (Politically Exposed Person), Sanctions, Adverse Media to fully compliant with AML regulations.

Is the ID document authentic and valid?

the ID photo?

Is the person physically present the transaction

Jumio Identity Verification delivers a definitive yes or no answer in seconds.

Risk Identified Description Controls in Place Reflected in Customer Risk Model

• Merchant • Identification, verification, full KYC data required for all users • Expected deposit level

• Complex Structures • Identification, verification, full KYC data required for all users • Name Screening against sanctions, PEP, adverse media • Enhanced due diligence for higher risk customers (verification of employment, source of funds) • Risk factors include employment, business sectors • Additional risk loading for customer for investment vehicles and complex structures. Delivery Channel Risk Non-Face-to-Face • Jumio – Biometric verification against ID photo and selfie taken during onboarding Geographical Risk Clients with linkage to countries subject to:

• High level of corruption • Certain countries prohibited from registration • Risk level assigned to each country according to recognised global organisations (e.g. FATF countries, Transparency International) and regularly updated country risk score based on Corruption Perceptions Index (CPI) • Residence country, citizenship, expected country of origin of funds

Himalaya Coin & Himalaya Dollar. Building Resilience for Canada's Main Aim in Cyber Security Landscape

borderless, inclusive and secure.