AML / KYC Policy

Definition

1. Money Laundering (ML): the process by which criminals attempt to conceal the origin and/or illegitimate ownership of property and assets derived from criminal activity.

2. Terrorism Financing: includes both legitimate and illegitimate money that is characterized by concealment of the origin or intended criminal use of the funds.

3. Know Your Customer (KYC): This includes obtaining and verifying customer identity, preserving customer records, and disclosing transactions to authorized statutory bodies.

4. Financial Transactions andReports Analysis Centre of Canada (FINTRAC): The Canadian FinancialIntelligence Unit, whose mission is to facilitate the detection, prevention, and deterrence of money laundering and terrorist financing while protecting personal information under its control.

5. Politically Exposed Persons(PEPs): Individuals who are or have been entrusted with prominent public functions in any country; generally posing a higher risk of potential involvement in bribery and corruption due to their position and influence.

6. Enterprise risk management(ERM): the methods and processes that organizations use to manage risks and capitalize on opportunities related to achieving their goals.

7. Client: Any entity with a business relationship with the Company or any entity involved in a financial transaction that may pose a significant reputational or other risk to the Company is considered a client.

Policy Mandates

TheAnti-ML & Combating the Financing of Terrorism Policy ("AML/CFTPolicy") establishes the guidelines for Brassview Tech Inc.'s (hereinafter referred to as 'the Company') compliance with AML/CFT obligations under the law as well as regulatory directives and prohibits any transaction that facilitates criminal activities

Policy Description

ML and terrorism financing are both financial crimes with economic consequences.The goal of this policy is to eliminate the negative effects of criminal economic activity while also promoting financial market integrity and stability. The Company's corporate integrity, reputation, and operational efficiency are all at stake if this policy is not followed

The Policy's purpose is to:

• Guide the standards of conduct and practice that must be followed in the implementation of the KYC

• To guard against fraud, reputational harm, and other financial market risks for the Company.

• To reduce the Company's exposure to financial crime proceeds by preventing money laundering and establishing ERM systems to monitor the Company's exposure to financial crime.

Compliance with policy

The following requirements must be met by the Company:

• Develop and implement internal controls and other procedures to deter criminals from using its facilities for money laundering and terrorist financing, as well as to ensure that its obligations under Canada and existing laws and regulations are met

• Begin ERM and keep an ERM register

• Designate an Officer with the relevant competence and independence to implement the Company's AML/CFT compliance policy.

• Adhere to the Money Laundering(Prohibition) Act, the Money Laundering (Prohibition) (Amendment) Act, and theEconomic and Financial Crimes Commission Act.

• Identify and report any suspicious transactions resulting from criminal activities as defined inAML/CFT Regulations;

• Ensure that the implementation of the AML/CFT Act is not hampered by the Company's Confidentiality Agreement or Policy

• Effectively communicate and raise staff awareness on AML/CFT issues.

Know your client

KYC is the due diligence that aCompany must perform in order to identify its clients and obtain relevant information before engaging in any financial transactions with them.

In order to maintain its KYC policies, the Company must do the following:

• Provide clients with a KYC compliance form.

• Collect all necessary documents and information from each client.

• Notify regulatory authorities of suspicious activities and transactions

• Update client information as it becomes available.

• Identify and verify the client's identity with reliable, independent source documents (e.g., passport data page, national ID card, voters card, and utility bills stating their current postal address, etc) data or information.

• Check with the CorporateAffairs Commission to confirm the legal status of business names, incorporated trustees, and corporations.

• Refuse to do business with"shell companies" as defined by International Conventions.

• Perform due diligence on high-risk clients, business relationships, or transactions, such as PEP, cross-border transactions, and business relationships.

Record Keeping and Reporting

The Company must keep a record of a customer's identification for at least five years after the account is closed or relations with the customer are severed; and upon request by a regulatory or law enforcement agency, the Company must make records related to AML/CFT compliance or its clients available as soon as possible from the date of the request.

If the company becomes aware of a criminal transaction, it must:

• Prepare a report identifying the principal and the beneficiary or beneficiaries

• Take appropriate action to prevent the laundering of criminal proceeds

• Send a copy of the report and action taken to the Financial Transactions and Reports Analysis Centre ofCanada (FINTRAC).

Politically Exposed Persons

Business relationships with PEPs' family members or close associates carry the same reputational risks as the PEPs themselves. When dealing with PEPs, the Company must assess the risks to its business operations.