Disclosure of compliance

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PURPOSE OF OUR PROGRAM

PGMMClub.com (“GMMCLUB”) has established and implemented an Anti-Money Laundering, Anti-Terrorist Financing and Economic and Commercial Sanctions Program (“AML / ATF / Sanctions Program” or “Program”) to ensure a robust, compliant and platform for the investment of digital value-added assets. We want to promote legal and transparent business activities and maintain a solid reputation among our customers, regulators and the digital asset industry.

OUR ROLE AND ACTIVITIES

We are a platform or global investment market for digital assets, where investors come as investors in the digital market, or are commonly referred to as market investors. For greater clarity, investors invest their digital assets with us as loan counterparts for Digital market operations. Our services are available through GMMClub.com, the associated application program interface and / or mobile applications (Site) and through operating entities, such as Global Money Management Company Limited, (incorporated in New Zealand) and Eyeline Corp Usa . (incorporated in the US).

Disclosure: the trade is risky. The risk of loss in the negotiation or possession of digital assets can be substantial. Therefore, you should carefully consider whether the negotiation is right for you in light of your financial situation.

REGULATORY LANDSCAPE

We understand that regulators have adopted a diverse approach to laws and regulations related to digital assets, including some that characterize or define digital assets as virtual currency, cryptocurrency or digital currency depending on the context of certain commercial activities. As a digital investment platform, we believe that bitcoin (as well as other alternative currencies) are digital assets that are emerging as an innovative alternative asset class; and therefore, digital assets should not be called money or currency.

Disclosure: digital assets are not money or fiat currency. While digital assets can have significant value, GMMCLUB does not consider digital assets as money or fiat currency. Digital assets such as bitcoin are NOT backed by any government or central bank. However, given that we provide a valuable feature to our clients who wish to invest we believe it is imperative to maintain a strong AML / ATF / Sanctions program as we connect with the financial fiduciary currency. system. Sometimes we can have opinions on the different regulatory approaches taken by various government agencies; however, at all times we will comply fully with the rules and regulations of the respective countries. We regularly reach regulators and the industry on the best approach to regulate digital asset businesses.

Disclosure: we cooperate with governments. While we can not accept the costly regulations themselves, we respect the regulations and comply with applicable regulations. As good corporate citizens, we may be asked for information from law enforcement authorities and we will help you if allowed by law. What this also means is that our platform is intended for law-abiding customers. We appreciate the opportunity to win your business and, in return, we ask you to act legally and appropriately on our platform. In addition, to promote a solid ecosystem, we have evaluated our clients (including usufructuaries) against entities / persons in the Government Gazette of the New Zealand Special Administrative Region, sanctions lists of the United States Office of Control of Foreign Assets (OFAC) and the United Nations List of Sanctions of the Security Council, among other lists of sanctions.

Disclosure: we do not accept certain clients. Our operating entities, such as Global Money Management Company Limited and Eyeline Corp Usa., Comply with applicable local and foreign laws and regulations. To maintain our solid reputation in the market and meet certain jurisdictions that have unique regulatory requirements for our operating entities, we have decided not to seek or accept clients from certain jurisdictions, such as Cuba, Iran, North Korea, Crimea, Sudan, Syria, Malaysia , Bangladesh, Bolivia, Ecuador and Kyrgyzstan. The last four countries have banned activities related to digital assets. We just do not want to disagree with the regulations of several countries. In addition, within the United States, we currently only provide our Service to users in California; more eligible states will come soon.

OUR AML / ATF PROGRAM

We have designed our Program to reasonably prevent money laundering and terrorist financing through a multi-layer control system based on risk. The first layer includes a strict client identification program, which includes verification of the identity of our clients, whether individuals or entities. In addition to obtaining identification documents, we obtain for non-physical persons the beneficiaries / individuals of their entities in accordance with international standards such as the Financial Action Task Force (FATF). The second layer includes a risk-based system to guarantee additional customer due diligence. The third layer includes a continuous monitoring of suspicious activities. If our Program suspects or has reason to suspect that suspicious activity has occurred at Eyeline Corp USA, we will file suspicious activity reports with the Financial Crimes Enforcement Network of the United States Department of the Treasury (FinCEN). If our Program suspects or has reason to suspect that suspicious activity has occurred at Global Money Management Company Limited, we will file suspicious activity reports with local regulators at our discretion. A suspicious transaction is often inconsistent with a client’s known and legitimate business or personal activities.

These are the main components of our compliance program; however, the most important snag or connection to these layers is our leadership team and staff, including the AML / Risk staff who perform training, supervision and a strong compliance culture. If you have any questions or need help with our clients’ due diligence controls, please do not hesitate to contact our customer service representatives 24 hours a day, 5 days a week, by chat or email at support @ GMMClub.com.

This “Disclosure of conformity” may have different language versions. If there is any difference between the different versions, the English version will prevail.

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