AML Policy

Introduction:
Stellaire Deux Limited, hereinafter referred to as " SiiSii.com" is committed to maintaining the highest standards of anti-money laundering (AML)
compliance. Our company, with its registered address at 77 Camden Street Lower Dublin 2 DUBLIN, DO2 XE80 Ireland, and operating under the brand
name Mystery Box | Unbox Authentic Products for up to 95% off |  SiiSii.com , is dedicated to preventing the use of its services for money laundering
purposes.

Objective of the Policy:
Our primary objective is to provide a secure environment for all users of  SiiSii.com. To achieve this, we regularly verify the identities of our customers
to ensure that their registration details are accurate and that the deposit methods used are legitimate and not associated with criminal activities. This
policy outlines our commitment to combating money laundering (ML) and the framework we have established to achieve this goal.
 SiiSii.com also implements reasonable measures to control and mitigate ML risks, allocating appropriate resources to maintain a robust AML
program.

Policy Compliance:
Our AML program is designed to align with relevant regulations and directives, including but not limited to:
1. European Union(EU) Directive 2015/849 on the prevention of the use of the financial system for money.
2. laundering. European Union(EU) Directive2015/849 on the prevention of the use of the financial system for.
3. money laundering. EU Regulation 2015/847 on information accompanying transfers of funds. EU regulations.
4. imposing sanctions or restrictive measures, including those on dual-use goods. Irish Law of 18 September.
5. 2017 on the prevention of money laundering and the limitation of the use of cash.

Policy Compliance:
Our AML program is designed to align with relevant regulations and directives, including but not limited to:
1. European Union(EU) Directive 2015/849 on the prevention of the use of the financial system for money.
2. laundering. European Union(EU) Directive2015/849 on the prevention of the use of the financial system for.
3. money laundering. EU Regulation 2015/847 on information accompanying transfers of funds. EU regulations.
4. imposing sanctions or restrictive measures, including those on dual-use goods. Irish Law of 18 September.
5.2017 on the prevention of money laundering and the limitation of the use of cash.
Money Laundering Definition:
Money laundering includes activities such as:
·The conversion or transfer of property derived from criminal activity to conceal its illicit origin.
●The concealment or disguise of the true nature, source, location, or ownership of property derived from criminal activity.
· The acquisition, possession, or use of property known to be derived from criminal activity.
●Participation in, association with, attempts to commit, aiding, abetting, facilitating, or counseling any of the aforementioned actions, even if the
underlying criminal activities occurred in another jurisdiction.
Organizational Structure:
In accordance with AML legislation, SiiSii.com designates the highest level of management, known as the "D Level Management," for the prevention of
money laundering. Additionally, an Anti Money Laundering Compliance Officer (AMLCO) is responsible for enforcing the AML policy and procedures
within the organization. The AMLCO reports directly to the Compliance Officer, who, in turn, reports to the Chief Executive Officer.
Policy Changes:
Any significant changes to  SiiSii.com AML policy must receive approval from the D Level Management.
Money Laundering Definition:
Money laundering includes activities such as:
●The conversion or transfer of property derived from criminal activity to conceal its illicit origin.
·The concealment or disguise of the true nature, source, location, or ownership of property derived from criminal activity.
●The acquisition, possession, or use of property known to be derived from criminal activity.
● Participation in, association with, attempts to commit, aiding, abetting, facilitating, or counseling any of the aforementioned actions, even if the
underlying criminal activities occurred in another jurisdiction.
Organizational Structure:
In accordance with AML legislation, SiiSii.com designates the highest level of management, known as the "D Level Management," for the prevention of
money laundering. Additionally, an Anti Money Laundering Compliance Officer (AMLCO) is responsible for enforcing the AML policy and procedures
within the organization. The AMLCO reports directly to the Compliance Officer, who, in turn, reports to the Chief Executive Officer.
Policy Changes:
Any significant changes to  SiiSii.com AML policy must receive approval from the D Level Management.
Enterprise-Wide Risk Assessment:
 SiiSii.com conducts an annual AML Enterprise-wide Risk Assessment (EWRA) to identify and understand risks specific to its business lines, products,
services, customers, transactions, and geographic locations. This risk assessment serves as the basis for the AML risk policy and is updated annually.
Know-Your-Customer(KYC)Standards:
 SiiSii.com has established KYC standards that require due diligence on all customers before they can receive items as offered on our platform. KYC
includes the verification of identity,representatives, and beneficial owners based on reliable and independent sources compliant with domestic and
European AML legislation and regulation. KYC is an ongoing process that includes dynamic data through the customer relationship.
Customer Identification and Verification:
The following documents are required for customer identification and verification:
1. A copy of the customer's passport, ID card, or driver's license, along with a handwritten note mentioning  SiiSii.com. All four corners of the ID must
be visible in the same image, and all details must be readable.
2. Proof of address, such as a recent utility bill issued within the last 3 months. The document must show the registered address and be clear and
readable.
Ongoing Customer Due Diligence:
Higher-risk customer categories undergo periodic risk-based reviews to ensure that customer-related data remains up-to-date. For other customer
categories, an awareness principle is applied, and periodic reviews are conducted based on the examination of a dedicated file by the AML team.
Ongoing Transaction Monitoring:
 SiiSii.com conducts ongoing transaction monitoring to detect unusual or suspicious transactions compared to customer profiles. This monitoring is
performed at multiple levels, including partnerships with trusted Payment Service Providers and additional checks for high-risk customers.
Suspicious Transactions Reporting:
 SiiSii.com has defined procedures for reporting atypical transactions. The AML team analyzes such reports and may decide to report to the Financial
Intelligence Unit(FIU) as required by law or terminate business relations with the customer, as appropriate.
Procedures and Record Keeping:
AML rules and minimum KYC standards are translated into operational procedures available on  SiiSii.com Intranet site. Records of customer
identification and transaction data must be kept for at least ten years after the business relationship has ended.
Training:
 SiiSii.com provides mandatory AML training for its staff in accordance with the latest regulatory requirements. New employees also undergo
academic AML learning sessions to ensure they are aware of their AML duties.
Auditing:
Internal audits regularly assess and report on AML activities within the organization to ensure compliance and effectiveness.
 SiiSii.com is committed to the highest level of AML compliance to protect our users and maintain the integrity of our services. We continuously adapt
our AML program to address emerging risks and regulatory changes.

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