Anti-Money Laundering and Fraud Prevention Statement

PULSECORE TECH LTD

Effective Date: 1 April 2026 | Version 1.0

Company: PULSECORE TECH LTD

Company Number: 17068502

Registered Address: 20 Wenlock Road, London, N1 7GU, England

AML Supervisor: [HMRC MLR Supervisor Reference — insert upon registration]

Contact: [email protected]

1. Policy Statement and Regulatory Framework

PULSECORE TECH LTD (“Company”) is committed to operating in full compliance with all applicable anti-money laundering (“AML”) and counter-terrorist financing (“CTF”) laws. The Company’s AML/CTF framework is built in accordance with:

• Proceeds of Crime Act 2002 (“POCA 2002”);
• Terrorism Act 2000;
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR 2017”), as amended;
• Sanctions and Anti-Money Laundering Act 2018 (“SAMLA 2018”);
• Financial sanctions orders and licences administered by His Majesty’s Treasury, Office of Financial Sanctions Implementation (“OFSI”);
• Financial Action Task Force (“FATF”) Recommendations.

This Statement is the public-facing summary of the Company’s AML and fraud prevention framework. The Company’s full internal AML policy and risk-based procedures are maintained separately and reviewed at least annually. AML supervision is provided by: [HMRC MLR Supervisor Reference — insert upon registration].

2. Business Risk Assessment

The Company has conducted a documented business-wide risk assessment in respect of the financial crime risks associated with the retail sale of digital goods (gaming codes and gift card codes). Digital goods present inherent risks by virtue of their near-instant delivery, non-reversible nature, and the ease with which they can be converted to value. The controls described in this Statement are designed to be proportionate to those risks.

3. Customer Due Diligence

3.1 Standard CDD

The Company applies standard customer due diligence (“CDD”) measures to all customers in accordance with Regulation 28 MLR 2017. At minimum, this includes collecting name, email address, billing country, and payment method details for every transaction.

3.2 Enhanced Due Diligence (“EDD”)

EDD measures are applied in higher-risk circumstances, including:

• transactions meeting or exceeding internal risk-based value thresholds;
• customers whose transaction behaviour is inconsistent with their stated profile;
• customers identified as Politically Exposed Persons (“PEPs”) or their known associates;
• customers from jurisdictions listed by FATF as high-risk or subject to increased monitoring;
• any other circumstances assessed as elevated risk by the Company’s compliance controls.

EDD may require submission of government-issued identity documentation, source of funds information, or additional account information. The Company reserves the right to decline to provide services where EDD requirements are not satisfied. In such cases, it may not be possible to provide a reason (see Section 7).

3.3 Ongoing Monitoring

The Company monitors existing customer relationships on an ongoing basis in accordance with Regulation 28(11) MLR 2017, including review of transaction patterns for consistency with each customer’s known profile and risk classification.

4. Sanctions Screening and PEPs

The Company screens customers and transactions against the UK Consolidated List of Financial Sanctions Targets (maintained by OFSI), the UN Security Council Consolidated List, and applicable PEP databases. Screening occurs at onboarding and on an ongoing basis.

The Company does not provide services to any person or entity subject to applicable financial sanctions. Where a match is confirmed, the Company will take immediate action in accordance with SAMLA 2018 and relevant OFSI guidance, which may include freezing the transaction and making a report to OFSI.

PEPs are not automatically refused service but are subject to mandatory EDD and senior management approval before any business relationship is established or continued.

5. Transaction Monitoring

The Company operates risk-based transaction monitoring to identify patterns indicative of money laundering, fraud, or other financial crime. Monitored indicators include but are not limited to:

• transaction volume or frequency that is inconsistent with a customer’s profile;
• multiple high-value purchases within a short period;
• use of multiple payment methods or cards associated with a single account;
• refund requests that are inconsistent with normal purchasing behaviour;
• use of anonymising technologies or access from sanctioned jurisdictions;
• patterns consistent with card testing, account takeover, or carding fraud.

Transactions triggering monitoring alerts may be held for manual review, delayed, or declined. Where additional information is required, the Company will contact the customer before proceeding, unless doing so would constitute tipping off (see Section 6).

6. Suspicious Activity Reporting

The Company has designated a Nominated Officer responsible for receiving internal suspicion reports and, where appropriate, submitting Suspicious Activity Reports (“SARs”) to the National Crime Agency (“NCA”) under Part 7 POCA 2002 and section 19 of the Terrorism Act 2000.

Under section 333A POCA 2002 (tipping off), the Company is legally prohibited from disclosing to any customer or third party that a SAR has been, is being, or may be submitted, or that an investigation is underway. Where the Company declines a transaction or is unable to give a reason, this may reflect obligations under this framework.

7. Right to Decline Without Explanation

Where disclosure of a reason for refusal would constitute tipping off under section 333A POCA 2002, or where the Company has formed a genuine suspicion of financial crime, the Company reserves the right to decline to fulfil an order or provide services without giving any explanation. The Company shall not be liable for any such refusal made in good faith in performance of its AML/CTF obligations.

8. Fraud Prevention

The Company employs layered fraud prevention controls including:

• automated fraud scoring and real-time transaction screening at the point of payment;
• velocity controls on purchases per account and per payment method;
• device and behavioural analytics;
• collaboration with payment processors on chargeback management and fraud intelligence.

The Company reserves the right to cancel any order or suspend any account where fraud is suspected. Where fraud is confirmed or highly probable, the matter may be reported to law enforcement.

9. Record Keeping

AML-relevant records are retained in accordance with Regulation 40 MLR 2017 for a minimum of 5 years from the end of the business relationship with the relevant customer, or 5 years from the date of the relevant transaction, whichever is later. Records are stored securely and made available to competent authorities upon lawful request.

10. Training and Governance

Personnel with AML/CTF responsibilities receive training proportionate to their role on a regular basis. Senior management is responsible for governance of the Company’s financial crime prevention framework and for ensuring that it is adequately resourced and reviewed.

11. Policy Review

The Company reviews this Statement and its internal AML policy at least annually and following any material regulatory development or business change. Updates are published on the Website.

12. Contact

AML and compliance enquiries:

PULSECORE TECH LTD (Company No. 17068502)

20 Wenlock Road, London, N1 7GU, England

Email: [email protected]

Website: https://orbiano.com