AML / CFT Policy

1. Purpose

The purpose of this Anti-Money Laundering, Counter-Terrorist Financing, Sanctions, and Anti-Fraud Policy ("Policy") is to establish the principles, controls, and internal procedures adopted by ORBITE HOLDING in relation to the Genius Home platform in order to prevent, detect, mitigate, and respond to risks involving:

• money laundering;
• terrorist financing;
• sanctions violations;
• fraud and financial crime;
• identity abuse or impersonation;
• unlawful settlement activity;
• other forms of misuse of the platform.

This Policy is designed to support lawful, transparent, and risk-aware operations and to promote safe onboarding, content monetization, settlement controls, and ongoing monitoring of creators, users, partners, and transactions associated with the Genius Home platform.

2. Scope

This Policy applies to:

• ORBITE HOLDING and the Genius Home platform;
• directors, officers, employees, contractors, and authorized representatives involved in creator onboarding, payments, settlements, finance, support, legal, operations, risk, or platform administration;
• individual and business content creators;
• settlement-related transactions and payout workflows;
• third parties engaged in payment processing, settlement, onboarding support, risk monitoring, or compliance functions, where applicable.

3. Business Model Context

Genius Home is a digital education and learning platform operated by ORBITE HOLDING. The platform may host, distribute, or monetize educational content, lessons, courses, books, audio content, assessments, training materials, and related digital offerings. Certain approved creators may be eligible to receive settlements or payouts in connection with their participation on the platform.

Because the platform may facilitate the movement or settlement of funds to third-party creators, ORBITE HOLDING recognizes the need to apply reasonable, proportionate, and risk-based controls to guard against misuse for illicit activity.

4. Policy Statement

ORBITE HOLDING has zero tolerance for the use of Genius Home for money laundering, terrorist financing, sanctions evasion, fraud, identity theft, proceeds of crime, unlawful content monetization, or any other illegal or abusive conduct.

ORBITE HOLDING is committed to:

• applying appropriate due diligence to creators and relevant counterparties;
• monitoring account activity and settlements on a risk-sensitive basis;
• maintaining internal controls and escalation procedures;
• investigating suspicious behavior or anomalous payment patterns;
• withholding, delaying, rejecting, or suspending settlement where justified;
• keeping appropriate records;
• cooperating with competent authorities and regulated partners where required.

5. Governance and Responsibility

6. Risk-Based Approach

ORBITE HOLDING applies a risk-based approach to compliance. This means the degree of review, verification, monitoring, and escalation may vary depending on the risk presented.

Risk factors considered may include:

• creator type: individual, institution, business, or intermediary;
• nature of content or business activity;
• expected and actual transaction values;
• volume and velocity of settlements;
• payout channel and destination;
• geography and jurisdiction;
• complexity of ownership or control structure;
• prior complaints, policy violations, or abuse indicators;
• adverse information, sanctions indicators, or suspicious behavior.

Higher-risk cases may be subject to enhanced review, additional documentation, manual approval, delayed settlement, or rejection.

7. Customer / Creator Due Diligence

8. Content and Platform Legitimacy Controls

Since Genius Home is a content-driven platform, compliance review also considers whether the creator's content and activity appear lawful and legitimate.

ORBITE HOLDING may review:

• content category and educational relevance;
• legality of subject matter;
• potential IP infringement;
• plagiarism or impersonation concerns;
• misleading or deceptive monetization conduct;
• prohibited or abusive content practices.

Creators whose content or conduct presents elevated legal, financial, or reputational risk may be restricted, suspended, or denied settlement.

9. Sanctions, Watchlist, and Restricted Activity Controls

ORBITE HOLDING may apply proportionate sanctions and restricted-party controls, including screening, internal checks, and review of adverse indicators where feasible and appropriate.

The platform may prohibit or restrict:

• persons or entities subject to sanctions or legal restrictions;
• activity involving prohibited jurisdictions, where applicable;
• activity linked to fraud, unlawful proceeds, identity misuse, or criminal behavior;
• settlements where recipient identity or ownership is unclear or inconsistent.

If a sanctions or restricted-party concern is identified, ORBITE HOLDING may suspend onboarding or settlement pending review.

10. Settlement and Payment Controls

11. Ongoing Monitoring

ORBITE HOLDING applies ongoing monitoring proportionate to the nature and risk of the relationship. Monitoring may include:

• review of creator activity and monetization behavior;
• complaint and incident review;
• account behavior analysis;
• periodic KYC refresh;
• reassessment of elevated-risk relationships;
• manual review where automated or operational triggers identify concerns.

12. Internal Reporting and Escalation

All staff involved in relevant functions must promptly escalate suspicious, unusual, or inconsistent activity to the designated responsible officer or management.

Escalations should be made where there is:

• suspected fraud;
• suspected false identity or forged documents;
• suspicious payout behavior;
• sanctions or restricted-party concern;
• material policy violation with financial implications;
• suspicion that the platform may be used to conceal or transfer illicit proceeds.

Internal reviews shall be documented, and decisions shall be recorded.

13. External Reporting and Cooperation

Where required by applicable law, regulation, contractual obligation with regulated partners, or lawful request by competent authorities, ORBITE HOLDING may:

• provide records or compliance information;
• report suspicious conduct;
• cooperate with payment providers, financial institutions, or public authorities;
• suspend access or freeze settlement activity to the extent legally and contractually permitted.

14. Record Retention

ORBITE HOLDING shall maintain records relevant to this Policy for a reasonable and legally compliant period, including:

• creator onboarding documentation;
• identity and business verification records;
• beneficial ownership information where collected;
• settlement instructions and payout details;
• transaction logs;
• internal review notes, suspensions, complaints, and escalation records;
• policy acknowledgements and training records.

Records may be kept in physical or electronic form, provided they remain retrievable, secure, and protected against unauthorized access or alteration.

15. Data Protection and Confidentiality

Information collected under this Policy shall be handled with appropriate confidentiality and in accordance with applicable data protection, privacy, contractual, and internal security requirements.

Access to sensitive compliance information shall be limited to authorized personnel with a legitimate need to know.

16. Staff Training and Awareness

Relevant staff and representatives shall receive suitable awareness and instruction on:

• creator due diligence requirements;
• settlement risk indicators;
• fraud and suspicious activity red flags;
• escalation procedures;
• documentation and recordkeeping expectations;
• sanctions and restricted activity controls, where relevant.

Training may be provided at onboarding and periodically thereafter.

17. Independent Review and Policy Updates

This Policy shall be reviewed periodically and updated as necessary to reflect:

• changes in business model;
• new payment arrangements or settlement flows;
• legal or regulatory developments;
• operational lessons learned;
• identified control weaknesses or emerging risks.

18. Non-Compliance

Any employee, contractor, or representative who fails to comply with this Policy may be subject to disciplinary, contractual, or other appropriate action, without prejudice to any legal obligations or remedies.

Any creator or counterparty who fails to cooperate with required due diligence, provides false information, or engages in suspicious or prohibited activity may be denied onboarding, suspended, or permanently removed from the Genius Home platform, and settlement may be withheld or rejected.

19. Reservation of Rights

ORBITE HOLDING reserves the right, subject to applicable law and contract, to:

• request additional information at any stage;
• delay, suspend, or refuse settlement;
• restrict access to platform services;
• impose enhanced due diligence measures;
• terminate relationships presenting unacceptable compliance, fraud, sanctions, or reputational risk.

20. Approval and Effective Date

This Policy is approved by ORBITE HOLDING LLC and entered into force on January 3, 2026.