AML Policy

Capital College Anti-Money Laundering and Know Your Customer Guidelines

The Company’s Commitment to AML Compliance:
Capital College LLC and it s associates are com m it ted to ensuring full compliance by the Company with all applicable federal and state laws and regulations, Self- regulatory organization rules and any other industry rulemaking authorities’ rules regarding anti- money laundering ( “ AML” ) .

The Company is responsible for ensuring that: ( i) the company keeps it s AML policy current and that each operating area implements and maintains procedures to detect and report possible money laundering and suspicious activity; and ( ii) all required governmental and
regulatory filings are completed accurately and submit ted t imely; and (iii) the Company fully complies with all applicable AML laws and
regulations.

The Company has the responsibility and authority to ensure that AML practices and procedures are consistent with the AML policy and
reasonably designed to satisfy the requirements of the policy and related regulatory requirements. In addition, any questions about this policy may be directed to support@capitalcollege.info.

Who I s Covered By The AML Program ?
The Anti- Money Laundering Program ( the “ Program ” ) is applicable to all aspects of the operations of the Company. The Program , as set forth in this Policy, is designed to address, among other things, the requirements of the Tit le III of the U. S. A Patriot Act ( the “ Money Laundering Abatement Act” ) , including:
• the development of internal policies, procedures, and controls;
• the designation of a compliance officer;
• an ongoing employee t raining program ;
• and independent audit function to test program s.

The Company continues to monitor regulatory and other
developments in the anti- money laundering area, and is firmly com m it ted to ensuring that all Company departments, affiliates, subsidiaries, agents, and employees are and remain in compliance with applicable law.



W hat Is Money Laundering?
Money Laundering is the process by which a criminal conceals the existence, source or nature of illegally derived funds to make them appear legitim ate. Money laundering typically occurs in three
stages: placement, layering and integration. Software platforms, financial services firms and other financial institution are at any point in the process susceptible to being used by criminals to carry out money laundering activities.
• Placement is the initial placement of illegal funds into the
financial system , norm ally in the form of currency or cash equivalents ( money orders, traveler’s checks, and bank
drafts.) Placement can occur when accepting a new account and the initial premium / deposit, subsequent payments and deposits, or third party receipts.
• Layering is the hiding or distancing of the illegal funds from
their source by creating transactions or a series of com plex transactions. Som e ways layering can occur include
processing multiple and frequent account transfers, ownership changes, or address changes.
• Integration is the ultimate disbursing of the “ clean”
proceeds back into society. At this point, the funds are likely to appear legitim ate and are disbursed from a legitim ate source.
Criminals often employ sophisticated methods of disguising the proceeds of their crimes, just as terrorists seek to funnel the
proceeds of ostensibly legitim ate businesses to fund and execute
terrorist plots. Terrorists and other criminals are increasingly using the facilities of securities firm s and insurance companies to conceal
the source of their funds. The concept of money laundering can also include the activities of individuals and businesses seeking to
conceal their earnings from the Internal Revenue Service and state and local taxing authorities.

Anti- Money Laundering Regulations
The United States Government principally administers and enforces anti- money laundering laws through the U. S. Treasury Department. As described below, depending on the type of financial institution, one or m ore of the following apply:

• Bank Secrecy Act ( BSA) - This federal law, and the
regulation enacted pursuant to the BSA includes requirements to report currency transactions, maintain specific records
including wire t ransfer documentation, report suspicious
activities, and maintain and implement anti- money laundering compliance with certain required elements. The BSA and
underlying regulations are enforced by the U. S. Treasury Departments Financial Crim es Enforcement Network ( FinCEN)

office. FinCEN m ay work together with parallel state and industry bodies, such as the Securities and Exchange
Commission ( SEC), to govern and monitor compliance with the law and applicable regulations.

• Internal Revenue Code ( I RC 6 0 5 0 1 ) - Thus section of the Internal Revenue Code has somewhat different reporting
requirements from what is required under the BSA. The
receipt of currency in an amount greater than $10, 000 in a single transaction, or in a series of related transactions , must be reported to the I RS on Form 8300.

• U.S.A Patriot Act- This federal law am ended the BSA so that the law now requires financial institutions to develop and
implement written anti- money laundering program s that include internal policies, procedures, and controls; a designated corporate counsel; provide an ongoing
employee t raining program ; and an independent audit of the program .

• OFAC- The Treasury Department’s Office of Foreign Assets Control ( OFAC) enforces carious statutes and regulations
prohibiting trade and financial/ commercial transactions with certain countries, their governments or officials, specially designated nationals ( SDNs), drug traffickers or terrorists.
OFAC identifies these individuals and entities on it s
Specifically- Designated Nationals and Blocked Nations List, which is continuously updated. Since September 11, 2001, hundreds of new entries have been added.


Consequences For Failure To Comply With AML Law s Failure to com ply with anti- money laundering and/ or OFAC laws and regulations m ay result in severe criminal and civil penalties against the Company and their respective employees and agents. Criminal and civil penalties can include imprisonment, substantial fines, loss of business licenses, and forfeiture of property involved. Employees and agents also may be subject to disciplinary action by the Company up to and including termination of employment for participating in such activities.



AML Compliance Procedures and Responsibilities
The corporate procedures for the Anti- Money Laundering Program include:

1. Screening
o Each client undergoes a screening process to collect necessary identification, including “liveness tests”. Clients are also compared to OFAC lists and blocked if they are subject to restrictions.
2. Documentation
o Information is stored for future use
3. Review
o Transactions are reviewed for irregularities
4. Notification
o In the case of concerns, counsel and the relevant authorities are notified

Ongoing Agent and Employee Training Program
The Company has developed an ongoing t raining program for agents and employees on anti- money laundering issues. The Company’s Anti- Money corporate counsel is responsible for the t raining program .
The t raining program is designed to familiarize employees and agents with the following:

• how to identify red flags and possible signs of money laundering that could arise during the course of duties;
• what to do once the instance of potential money laundering is identified;
• what their roles are in the Company’s compliance efforts;
• how to perform their roles;
• the Company’s record retention policy;
• possibility of disciplinary action by the Company upon the discovery of knowing or intentional participation in money laundering; and
• threat of government disciplinary action, including civil and criminal penalties for non- compliance with applicable laws and regulations.

Training for agents and employees will be conducted no less than annually. The Company’s corporate counsel m ay delegate
responsibility for individual t raining activities in certain instances. I n addition, the Company will properly document any delegation of
responsibility for the t raining program .

II . AN TI - MON EY LAUN DERI N G GUIDELIN ES
The anti- money laundering guidelines outlined below are applicable to the operations of the Company

Agents’ and Employees’ Obligations For AML Compliance Capital College LLC agents and employees have an obligation to avoid transactions with individuals or organizations ( e. g., partnerships, t rusts, corporations, joint ventures) that seek to use Company services and products to launder money or otherwise carry out illegal activities. Company personnel must be careful to avoid
receiving the proceeds of, or unwittingly aiding in transactions linked to criminal activities of any kind.
Suspicious Activity Monitoring and Reporting
Som e financial institutions are required by law to report “ suspicious activity” at their institutions on “ Suspicious Activity Report” form s
( “ SARs” ) . SARs are to be filed with FinCEN.

The Company will apply due diligence in an effort to make an inform ed decision about the suspicious nature of particular transactions and other activities in determining whether to file an SAR in a particular situation.

The Company will file SARs for any transactions conducted or attempted by, at or through the Company involving ( separately or in the aggregate) funds or assets of $ 5, 000 or m ore for which the Company detects any
known or suspect federal criminal violation involving the Company; or the Company knows, suspects, or has reason to suspect that the transactions:

• involves funds related to illegal activity;
• is designed to evade Bank Secrecy Act or other anti- money laundering rules or regulations;
• has no business or apparent lawful purpose and the Company knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction; or
• is the result of computer system intrusions.

Notwithstanding the $5, 000 threshold described above, the Company will file SAR and, when appropriate, notify law enforcement authorities of all
transactions where there is a suspicion that the proceeds of criminals, terrorists or other corrupt activities may be involved.

The Company will in all cases keep SARs and any supporting
documentation confidential. The Company will not inform anyone outside of law enforcement or regulatory agency or securities regulator about a SAR. The Corporate Compliance Department is responsible for filing and maintaining copies of all SARs and supporting documentation.

Cash Reporting
A principal method used by the Federal government to detect money laundering is to require financial institutions and other businesses to report the receipt of currency or cash equivalents ( such as cashier’s check, money orders, bank drafts, or traveler’s checks) Other laws
require financial institutions to report certain situations involving the use of a com bination of currency and/ or cash equivalents, each of which is
valued at $10, 000 or less, but which together total m ore than $10, 000.
When there is a reportable event, the company will file I RS Form 8300
( “ Cash Received in a Trade or Business” ) . Also, Company policy prohibits

customers and policyowners from using currency ( U. S. or otherwise) to pay for securities transactions and procedures are in place to ensure that currency is not accepted as payment in such transactions. However, the company typically does not engage in cash transactions.

Recognizing and Preventing Structured Transactions
Financial institutions, including insurance companies and broker- dealers, are required by law to report transactions, which are structured to avoid the various reporting requirements. Structuring includes the breaking down of a single sum or currency that exceeds $10, 000 into smaller
amounts and engaging in multiple transactions, each below $10, 000. Active assistance in structuring or passive acceptance of transactions designated to circumvent reporting requirements is also against the law. Violation could lead to civil fines and criminal penalties for the Company, the agent and employee.

The following are examples of activity which might suggest structured transactions involving currency and/ or cash equivalents
totaling over $10, 000 that must be reported:
• the client makes large, unscheduled deposits in rapid succession for new employees

I f the Company. agent or employee detects an attempt to structure transactions or suspects that transaction structuring is occurring, he/ she should immediately bring it to the attention of company counsel.

Know Your Custom er Rules
The concept of Know Your Custom er ( KYC) is critical in both the
securities and non- securities aspects of our business. As general rule, the Company gathers inform at ion about the clients. The inform at ion required under NASD Rules ( applicable to broker- dealer activities) is the starting point for anti- m oney laundering custom er identification procedures.

It is Company policy to:
• obtain the required custom er inform at ion ( name, address, tax identification number and date of birth) prior to opening new accounts;
• maintain records of the required custom er inform at ion; and

• Check that a policyowner or custom er doed not appear on any list of known and suspected terrorists or terrorist organizations such as
those persons and organizations listed on the OFAC Web Site under “ Terrorists” or “ Specially Designated Nationals and Blocked
Persons” ( SDN List), as well as the listed embargoed countries and regions ( collectively, the OFAC List).

Because of the risk that the prospective policyowner or custom er could be involved in criminal activity, the Company will consider, depending on the nature of the proposed transaction, not effecting a transaction prior to
verifying inform at ion about the custom er. I n addition, if a potential or
existing custom er either refuses to provide the inform at ion requested by the Company, or it appears to have intentionally provided misleading
inform at ion, The Company will not open an account and the corporate counsel must be notified so that a determination can be made as to whether the circumstances should be voluntarily reported to FinCEN or OFAC.

OFAC Country List Screening and Procedures

It is the policy of Capital College to prohibit transactions from persons or organizations from OFAC or High Risk countries including:

Afghanistan OFAC
Balkans OFAC
Belarus OFAC
Burma OFAC
Burundi OFAC
Central African Republic OFAC
Crimea (Region of Ukraine) OFAC
Republic of Congo OFAC
China OFAC
Cuba OFAC
Ethiopia OFAC
Hong Kong OFAC
Iran OFAC
Iraq OFAC
Lebanon OFAC
Libya OFAC
Myanmar OFAC
Nicaragua OFAC
North Korea OFAC
Russia OFAC
Somalia OFAC
Sudan OFAC
Syria OFAC
Ukraine OFAC
Venezuela OFAC
West Bank OFAC
Yemen OFAC
Bulgaria High Risk
Burkina Faso High Risk
Cameroon High Risk
Croatia High Risk
Haiti High Risk
Kenya High Risk
Mali High Risk
Monaco High Risk
Mozambique High Risk
Namibia High Risk
Nigeria High Risk
Philippines High Risk
Senegal High Risk
South Africa High Risk
Tanzania High Risk
Vietnam High Risk

The company has put the following procedures in place to screen, block and report OFAC list non-compliance.

1. Capital College only accepts deposits from clients with United States domestic bank accounts. These clients are de-facto based in the United States and not in prohibited OFAC countries.
2. Capital College monitors the IP address of all app users and only permits users to download the app from the Google Play Store or Apple App Store (which also prohibit users from sanctioned countries). Users with IP addresses in sanctioned countries are blocked from use of the application.
3. We do not allow users with Virtual Private Networks (VPNs) that hide IP addresses to download our app.
4. In the case that an IP address from a sanctioned country appears, we will notify appropriate authorities and counsel.

Prohibition on U.S. Correspondent Accounts With Foreign Shell Banks

Capital College LLC is prohibited from establishing, maintaining, administering, or managing a “ correspondent account” in the United States for an unregulated foreign shell bank. The term “ correspondent account” is broadly defined as an “ account established to receive deposits from or make payments on behalf of a foreign financial institution, or handle other financial transactions related to such institution.”