AML & KYC Policy

1. PURPOSE & SCOPE

Alpha Quant Systems Inc. ("ALPHA") maintains a comprehensive Anti-Money Laundering (AML) and Know Your Customer (KYC) programme to protect the integrity of its platform and comply with applicable Canadian federal and provincial regulations. This policy applies to all users seeking to access the ALPHA Customer Portal, subscribe to analytical services, or purchase software licenses.

2. MANDATORY IDENTITY VERIFICATION

All users must successfully complete the ALPHA Identity Verification process before gaining access to any gated services. This process includes:

• Government-Issued ID: A valid, unexpired passport, driver's licence, or national identity card.
• Selfie Verification: A real-time photograph matched against the submitted ID using encrypted third-party verification technology.
• Personal Details: Full legal name, date of birth, email address, mobile phone number, and country of residence.
• Address Verification: Residential address confirmation as part of the onboarding questionnaire.

3. RISK-BASED APPROACH

ALPHA applies a risk-based approach to customer due diligence. Standard verification is applied to all users. Enhanced Due Diligence (EDD) may be triggered by:

• Users located in high-risk jurisdictions as defined by FATF or Canadian sanctions lists.
• Unusual transaction patterns or multiple failed payment attempts.
• Discrepancies between submitted identity documents and verification results.
• Politically Exposed Persons (PEPs) or individuals with adverse media mentions.

4. PROHIBITED JURISDICTIONS

ALPHA does not provide services to users located in jurisdictions subject to comprehensive sanctions by Canada, the United States, or the European Union. ALPHA reserves the right to refuse or terminate service to any user based on jurisdictional risk assessment.

5. ONGOING MONITORING

ALPHA conducts ongoing monitoring of user activity to detect suspicious behaviour, including but not limited to:

• Multiple account registrations from the same IP address or device.
• Rapid successive failed payment attempts.
• Credential sharing or concurrent access from multiple geographic locations.
• Attempts to circumvent hardware-locked licensing controls.

6. SUSPICIOUS ACTIVITY REPORTING

Where required by applicable law, ALPHA will file Suspicious Transaction Reports (STRs) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) or other relevant authorities. ALPHA is prohibited from notifying users that a report has been filed ("tipping off").

7. RECORD RETENTION

KYC documentation and transaction records are retained for a minimum of seven (7) years following account closure or the last transaction, in compliance with Canadian regulatory requirements. Biometric verification data is processed by encrypted third-party providers and handled according to their industry-standard deletion schedules.

8. RIGHT TO REFUSE SERVICE

ALPHA reserves the absolute right to refuse account activation, suspend access, or terminate service to any user who fails to provide satisfactory identity documentation, provides false or misleading information, or whose activity triggers AML red flags. No refund will be issued in cases of termination for suspected fraudulent or illegal activity.