Anti-Money Laundering (AML) Policy

ARK Capital Inc. is firmly committed to the prevention of money laundering, terrorist financing, and all other forms of financial crime. We take our legal and ethical responsibilities seriously and maintain a zero-tolerance approach to facilitating illicit financial activity through our platform.

This AML Policy applies to all ARK Capital employees, contractors, officers, directors, and agents, as well as to all clients and counterparties engaging with the ARK Capital platform. All parties are expected to cooperate fully with our compliance procedures.

ARK Capital's AML program is designed to comply with the following regulatory frameworks and guidelines:

• FinCEN — Financial Crimes Enforcement Network (U.S. Department of the Treasury)
• BSA — Bank Secrecy Act (31 U.S.C. §§ 5311–5336)
• FATF — Financial Action Task Force Recommendations (40 Recommendations)
• GDPR — General Data Protection Regulation (EU) 2016/679, where applicable
• USA PATRIOT Act — Title III, Anti-Money Laundering provisions

Our AML program is reviewed annually by our Chief Compliance Officer and updated as required to reflect changes in law, regulation, or best practice guidance.

ARK Capital applies a risk-based approach to Customer Due Diligence. All clients are subject to standard CDD procedures before they may access investment features. Enhanced Due Diligence (EDD) is applied to clients identified as presenting a higher risk of money laundering or terrorist financing.

Standard CDD measures include:

• Verification of identity using reliable, independent source documents
• Verification of residential address
• Assessment of the nature and purpose of the business relationship
• Ongoing monitoring of transactions throughout the relationship

Enhanced Due Diligence is applied to high-risk clients, including Politically Exposed Persons (PEPs), clients from high-risk jurisdictions, and those seeking to make large or unusual transactions.

Our KYC program is the cornerstone of our CDD framework. All clients must complete KYC verification before accessing any investment features on the platform. KYC procedures include:

• Identity Verification:Government-issued photo ID (passport preferred; national ID card or driver's license accepted)
• Proof of Address: Utility bill, bank statement, or government letter dated within the last 3 months
• Source of Funds: Required for deposits exceeding $10,000 — bank statements, payslips, or tax returns
• Ongoing Monitoring: KYC records are reviewed at regular intervals and on detection of significant changes in client behaviour

ARK Capital uses a combination of automated identity verification technology and manual review by our compliance team to assess KYC submissions.

ARK Capital employs a real-time transaction monitoring system that analyses all deposits, withdrawals, and trading activity against a defined set of risk parameters and typology-based rules. The system generates automated alerts when transactions exhibit patterns associated with money laundering or other financial crime, including:

• Unusually large or frequent deposits inconsistent with a client's profile
• Rapid movement of funds (layering behaviour)
• Transactions involving high-risk jurisdictions or sanctioned entities
• Structuring of transactions to avoid reporting thresholds
• Activity inconsistent with a client's stated source of funds or investment purpose

All alerts are reviewed by our Compliance Team. Where suspicious activity is confirmed, appropriate action is taken in accordance with our Suspicious Activity Reporting procedures.

ARK Capital is a financial institution subject to mandatory Suspicious Activity Report (SAR) filing obligations under the Bank Secrecy Act. Where our Compliance Team identifies or suspects money laundering, terrorist financing, or other reportable financial crime, we are legally required to file a SAR with the Financial Crimes Enforcement Network (FinCEN) within 30 calendar days of initial detection.

ARK Capital is prohibited by law from disclosing to any client or third party that a SAR has been or may be filed in relation to their account (the “tipping off” prohibition). Filing a SAR does not constitute an accusation of wrongdoing; it is a legal obligation triggered by the presence of suspicious indicators.

ARK Capital maintains comprehensive records of all client onboarding documentation, KYC materials, transaction data, and compliance decisions for a minimum period of 5 years from the date of account closure or the date of the relevant transaction, whichever is later, in compliance with BSA and FinCEN record retention requirements.

Records are stored securely with access restricted to authorised compliance personnel. All records are available to regulators and law enforcement upon lawful request.

All ARK Capital employees with client-facing or compliance responsibilities are required to complete comprehensive AML training on an annual basis. Training covers:

• Applicable AML laws and regulations
• Recognition of money laundering typologies and red flags
• ARK Capital's internal CDD and SAR procedures
• Sanctions screening obligations
• Consequences of non-compliance

Training completion is tracked and recorded. Failure to complete mandatory training may result in disciplinary action.

Politically Exposed Persons — defined as individuals who hold or have held prominent public positions, as well as their immediate family members and known close associates — present a heightened risk of involvement in bribery, corruption, and related money laundering.

ARK Capital applies Enhanced Due Diligence to all PEP clients and their associates, including:

• Senior management approval required before onboarding
• Enhanced source of wealth and source of funds verification
• Increased frequency of ongoing monitoring
• Annual review of the business relationship

ARK Capital screens all clients, beneficial owners, and transaction counterparties against the following sanctions lists at account opening and on an ongoing basis for each significant transaction:

• OFAC — U.S. Office of Foreign Assets Control (SDN List and Consolidated Sanctions List)
• UN — United Nations Security Council Consolidated Sanctions List
• EU — European Union Consolidated Financial Sanctions List
• HMT — UK HM Treasury Financial Sanctions List

Any match against a sanctions list will result in immediate account suspension pending review. ARK Capital does not conduct business with sanctioned individuals, entities, or jurisdictions. Violations may be reported to the relevant authority.

Where a client fails or refuses to provide information or documentation required for CDD, KYC, or ongoing monitoring purposes, ARK Capital reserves the right to:

• Suspend or restrict access to the client's account
• Freeze all pending transactions
• Terminate the client relationship
• File a Suspicious Activity Report with FinCEN

Non-cooperation in itself may be treated as a suspicious indicator under our risk assessment framework. ARK Capital will act in accordance with its legal obligations in all such cases.

For AML-related enquiries, compliance matters, or to report concerns about potential financial crime, please contact our Compliance Team:

Email: compliance@arkcapital.com

ARK Capital Inc., 340 Pine Street, Suite 800, San Francisco, CA 94104