AML Policy and Compliance Program Overview

FOXO Development Corp is committed to preventing and detecting money laundering, terrorist financing, and sanctions violations. We are in the process of registering as a Money Services Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Our policies and procedures are designed to comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated Regulations.

1. Compliance Program: We have developed a comprehensive compliance program that includes:

   - Designation of a Compliance Officer

   - Written compliance policies and procedures

   - Risk assessment and mitigation strategies

   - Ongoing compliance training program

   - Plans for regular review and assessment of our compliance program's effectiveness

2. Risk-Based Approach: We have established processes to assess and manage risks related to money laundering, terrorist financing, and sanctions violations using a risk-based approach.

3. Customer Due Diligence (CDD): Our policies include thorough due diligence procedures for all customers, including:

   - Customer identity verification methods aligned with Canadian regulations

   - Assessment of business activities

   - Identification of ultimate beneficial owners

   - Screening against sanctions and politically exposed persons (PEP) lists

4. Enhanced Due Diligence (EDD): We have procedures in place for additional measures for high-risk customers, including those identified as PEPs or from high-risk jurisdictions.

5. Transaction Monitoring: We have developed systems to monitor customer transactions and account activity to detect suspicious patterns and ensure sanctions compliance.

6. Sanctions Compliance: Our policies adhere to sanctions regimes imposed by the UN, EU, UK, OFAC, and Canada. We will screen customers and transactions against relevant sanctions lists.

 7. Reporting: We have established procedures to report large transactions, suspicious activities, and potential sanctions violations to FINTRAC as required by Canadian law, once our MSB registration is complete.

8. Record Keeping: We have systems in place to maintain accurate records of customer information, transactions, and compliance activities for the required retention period as specified by Canadian regulations.

9. Staff Training: We have developed a training program to ensure our employees are knowledgeable about AML/CTF policies, sanctions compliance, and relevant regulations, with a focus on Canadian legislative requirements.

10. Ongoing Compliance: We are committed to regularly reviewing and updating our policies and procedures to align with FINTRAC guidelines and regulatory changes.

FOXO Development Corp is committed to operating in full compliance with all applicable AML/CTF and sanctions regulations. We are in the process of finalizing our registration as an MSB with FINTRAC and will implement all aspects of this compliance program upon receiving our registration.

For any questions regarding our AML, Sanctions, or Customer Due Diligence policies, please contact our Compliance team at [email protected].