AML Policy

1. Purpose and Scope

The purpose of this AML Policy is to mitigate the risk of Appia Solutions FZCO (hereinafter "we", "us", "our", "Company", "Jiggle") services being used to facilitate money laundering, terrorist financing, fraud, bribery, corruption or any other criminal activity.

The Company has implemented this AML Policy to ensure that appropriate procedures and controls are in place to support compliance with applicable laws and regulations.

Jiggle is a technology provider offering non-custodial software solutions for managing digital assets. Jiggle provides functionality that enables end-users to initiate cryptocurrency transactions. However, the Company does not have access to or control over end-users' transactions and does not receive any payments from end-users. Jiggle does not sell or purchase cryptocurrencies and does not control end-users' assets or transactions. The Company's services are strictly limited to the technical provision of a user interface that facilitates access to third-party services.

The Company's software allows end-users to create their own non-custodial wallets. The Company does not provide payment or exchange services. For all other services, including exchange services, the Company acts solely as an intermediary, while Third-Party Providers offer such services directly to end-users.

Considering the limited role and responsibilities of Jiggle, the Company does not require a financial or cryptocurrency exchange license, is not required to be regulated as a Virtual Asset Service Provider or Crypto Asset Service Provider and does not require AML registration for the services being offered.

Notwithstanding the above, and although the adoption of this Policy is not a legal requirement for the Company, Jiggle has implemented it as part of its commitment to maintaining high standards of integrity, transparency, and ethical business conduct. This Policy is intended to establish clear internal guidelines, promote responsible business practices, and mitigate potential legal, regulatory, and reputational risks.

2. Compliance Framework and Financial Crime Prevention

Jiggle adopts a zero-tolerance approach to bribery and corruption. The Company prohibits any form of bribery, facilitation payments, kickbacks, or other improper advantages, whether offered, given, requested, or received, directly or indirectly, in connection with its business activities. All employees, contractors, and partners are expected to act in good faith, comply with applicable laws and regulations, and uphold the principles of fairness, honesty, and accountability in all interactions.

Jiggle takes into account applicable sanctions regimes and international restrictions. As part of its risk-based approach, the Company prohibits access to its services to end users who are residents of or otherwise connected to any Prohibited Countries.

3. Service Limitations and Role of the Company

Jiggle does not and cannot provide customer support of any kind for transactions between end-users and Third-Party Providers, including, but not limited to, customer support regarding identification procedures (KYC) and transaction monitoring. Any contractual agreements, terms, and conditions applicable to transactions between end-users and Third-Party Providers are governed by the relevant agreement(s) in place between end-users and Third-Party Providers. Jiggle does not request, verify and collect KYC information of end-users.

Jiggle does not facilitate transactions. Instead, Jiggle provides technical infrastructure that enables end-users to access various Third-Party Providers. End users independently initiate and complete any transactions through those Third-Party Providers. Accordingly, Jiggle is not involved in the initiation, negotiation, execution, or settlement of any transactions between end-users and Third-Party Providers.

4. Third-Party Providers

The Company conducts identification and verification of Third-Party Providers, i.e. legal entities which are partnered with Jiggle.

All Partners are required to undergo a due diligence process and provide all necessary information and documentation as requested by the Company. Jiggle shall identify and verify the UBOs of each Partner and obtain a clear understanding of the Partner's ownership and control structure.

All the information and documents provided by the Partner shall be completely clear and readable. The Partner agrees to provide additional information and documents at the request of the Company within a reasonable timeframe.

Jiggle reserves the right to apply enhanced due diligence measures to Partners associated with certain jurisdictions classified as high-risk in accordance with applicable regulatory standards. In case of any suspicious activity, false documents or non-cooperation by the Partner within the due diligence process, the Company reserves the right to reject the Partner's documents and terminate the business relationship.

Jiggle is prohibited from establishing or maintaining any relationships with entities incorporated in, or otherwise connected to, Prohibited Countries. Jiggle conducts periodic screening of its Partners against applicable international sanctions lists.

Third-Party Providers are responsible for conducting customer identification procedures and transaction monitoring. They are required to comply with applicable KYC and AML laws and regulations. These processes are governed by the Third-Party Providers' own policies, and Jiggle does not process or store such data.

5. Policy Review and Updates

This document will be reviewed once per year. It may be amended or supplemented as necessary to reflect legislative, regulatory, or operational changes. All amendments and additions must be reviewed and approved by the management prior to implementation. Any changes will be submitted to the Board for review.

Published 3rd July 2026