Anti-Money Laundering & Counter-Terrorist Financing Policy

Solo Clash L.L.C-FZ ("Solo Clash", "we") will not let its platform be used to launder money, finance terrorism or proliferation, or evade sanctions. This policy sets out how we prevent, detect and report that activity.

Voluntary programme. Solo Clash is not a financial institution, designated non-financial business or virtual asset service provider under the AML laws of the UAE. It is not legally required to maintain AML procedures. Solo Clash adopts this policy voluntarily, as a risk-based standard, to protect its customers, its payment partners and itself. Nothing in this policy should be read as a statement that Solo Clash is a regulated or supervised entity.

1.1 Who we are. Solo Clash is registered in the Meydan Free Zone, Dubai, UAE (licence no. 2538558.01). Solo Clash sells access to simulated training programmes and trading evaluations ("Challenges") and pays rewards ("Payouts") to traders who meet the programme eligibility rules. Solo Clash does not accept deposits, hold client funds, or execute live trades on customers' behalf.

1.1a Third-party payment processing. Solo Clash does not process payments itself. Challenge fees are collected, and refunds made, through Paymid, a payment orchestrator, and the payment service providers (PSPs) it routes transactions to. Payouts are made through TTS and Rise, outside the Solo Clash platform: Solo Clash approves a Payout, and the trader receives it through their own TTS or RiseWorks account. These providers carry out identity verification, sanctions, PEP and payment screening under their own legal obligations. They do not share the results with Solo Clash, and Solo Clash cannot ask them to run checks or hold payments. Solo Clash does not screen customers against sanctions or PEP lists itself. Its own controls are limited to its platform, as set out in this policy.

1.2 Purpose. This policy:

1. Sets the minimum standards for identifying and verifying customers.
2. Defines how we assess and manage money laundering (ML), terrorist financing (TF), proliferation financing (PF) and sanctions risk.
3. Sets controls on money coming in (Challenge fees) and going out (Payouts, refunds, affiliate commissions).
4. Defines how suspicions are escalated, investigated and reported.
5. Assigns responsibility and sets training and record-keeping standards.

1.3 Scope. This policy applies to:

• All customers, including traders, prospective traders and anyone paying on a trader's behalf.
• Affiliates, introducing partners and content creators paid by Solo Clash.
• All directors, employees, contractors and outsourced providers acting for Solo Clash.

1.4 Definitions.

1.5 Precedence. Where local law in a jurisdiction we serve sets a higher standard, that standard applies. This policy forms part of the Solo Clash Terms and Conditions, and customers accept it by registering.

This policy is built primarily on UAE law, where Solo Clash is licensed, and on FATF standards.

2.1 Status of Solo Clash. Solo Clash provides simulated trading evaluations. It is not a bank, broker, payment service provider or virtual asset service provider, and it is not an obliged entity under UAE AML law. The instruments above are used as a reference standard, not because they bind Solo Clash as a regulated firm. Solo Clash follows them where they are practical for its business and where its payment partners require it.

2.2 Criminal law applies to everyone. Regardless of obliged-entity status, UAE law criminalises money laundering and dealing in criminal proceeds. Staff who know or suspect such activity must follow section 11.

Solo Clash's main ML risk is not in trading, which is simulated, but in the money flows around it. Fees come in from a global customer base. Payouts, refunds and affiliate commissions go out, sometimes by crypto.

Money flow:

1. Customer pays the Challenge fee through Paymid and PSPs, which apply their own checks.
2. Solo Clash applies its platform controls and runs the simulated evaluation.
3. If the rules are met, Solo Clash decides whether to approve the Payout; if not, the account ends.
4. An approved Payout is paid through TTS or Rise, which apply their own checks.

Controls sit in two layers that do not share information. Paymid, PSPs, TTS and RiseWorks check people and payments on their side. Solo Clash controls its own platform: who can open an account, where they connect from, how accounts link to each other, how they trade, and whether a Payout is approved at all. Solo Clash's main lever is its decision not to approve a Payout.

3.1 Key ML/TF typologies for prop firms.

3.2 Overall rating. The inherent ML/TF risk of the business is assessed as medium. It is mitigated by the absence of client deposits, by the checks Payment Providers apply to every transaction and Payout, and by Solo Clash's platform controls. The Compliance Officer reviews this rating at least annually.

The Managing Director owns this policy and appoints a Compliance Officer to run it day to day. The Compliance Officer may hold any payout or restrict any account while a concern is reviewed.

4.1 Who can hold the role. The Compliance Officer may be the Managing Director, another staff member, or an outsourced provider. Where the role is outsourced, decisions are still made in Solo Clash's name. If the Compliance Officer is unavailable, the Managing Director covers the role.

4.2 Selecting Payment Providers. Solo Clash uses Paymid for Challenge fees and refunds, and TTS and RiseWorks for Payouts. It expects each to be licensed or registered in its home jurisdiction, or to route through providers that are, and to run its own AML, sanctions and PEP programme. Solo Clash does not receive their screening results and cannot direct their checks. Every decision in this policy is therefore based on Solo Clash's platform data. Solo Clash reviews its payment arrangements at least annually, and before adding a new provider.

4.3 Review of the programme. Solo Clash may, at its discretion, ask an independent adviser to review how well this policy works in practice.

Every customer gets a risk rating of Low, Medium or High, based on Solo Clash's platform data. The rating sets how closely the account is reviewed before a Payout is approved.

5.1 Enterprise-wide risk assessment. The Compliance Officer documents Solo Clash's ML/TF/PF and sanctions risks at least annually. It covers customers, geographies, products, payment channels and delivery channels. It is also refreshed before launching a new product, payment method or market.

5.2 Customer risk factors.

5.3 Rating outcomes.

5.4 Triggers for re-rating. Repeated failed transactions; a chargeback; a change of country or IP pattern; a new account link; a monitoring alert; or crossing a payout threshold. Any move to High is reviewed manually.

Identity verification and screening, where they happen, are carried out by Paymid and PSPs (for fees) and by TTS and RiseWorks (for Payouts), not by Solo Clash, and the results are not shared. Solo Clash's own due diligence uses platform data and, where needed, information requested directly from the customer.

6.1 Checks by stage.

Paymid and the PSPs apply their own checks to each fee and refund, and TTS and RiseWorks apply their own onboarding and checks before paying a trader. Solo Clash is not told the outcome of those checks.

6.2 Identity documents. Solo Clash does not routinely collect or store identity documents. Where an enhanced review (section 7) needs them, RiseWorks may ask the customer to provide identification directly, and holds it under section 12.

6.3 One person, one profile. Each natural person may hold only one profile. Several Challenges may sit under it. Payouts may only be received by the account holder, through their own TTS or RiseWorks account. Duplicate profiles, or using another person's identity, result in closure of all linked accounts.

6.4 Entities. Solo Clash serves individuals only. Accounts may not be opened or paid for by companies, trusts or other legal arrangements, except affiliates onboarded under section 12.

6.5 Failed transactions. If a fee or refund fails through Paymid, or a Payout cannot be completed through TTS or Rise, Solo Clash does not try to complete it by another route. Repeated failures are treated as a red flag (section 10).

6.6 Information requests. Where platform data raises a concern, Solo Clash may ask the customer directly for an explanation or supporting information, for example about their country of residence or linked accounts. Customers must keep their account details up to date.

High-risk accounts get an enhanced review and need Compliance Officer sign-off before any Payout. The review uses platform data, plus information requested from the customer.

7.1 Triggers. An enhanced review applies when any of these occur:

• Platform data links the customer to a FATF "increased monitoring" jurisdiction.
• Challenge purchases exceed USD 10,000 in any 30 days, or payouts exceed USD 50,000 in any 12 months.
• The customer tells Solo Clash they are a PEP, or this becomes known to Solo Clash from public information or from a partner.
• A monitoring alert in section 10 is not resolved by standard review.
• The customer is rated High under section 5.

7.2 Review measures. The Compliance Officer decides which measures apply:

1. Detailed review of trading activity and account links across all the customer's Challenges.
2. A request to the customer for an explanation of their activity and, where spend is high, the source of the funds used for Challenge fees.
3. A request to the customer for identification, where identity is in doubt.
4. Not approving the Payout while the review is open.
5. Compliance Officer approval to continue the relationship, recorded with reasons.

7.3 PEPs. Solo Clash does not screen for PEP status and does not receive PEP screening results from Paymid, PSPs, TTS or RiseWorks. Where Solo Clash learns that a customer is a PEP, from the customer or from public information, the account is rated High and reviewed under this section. Being a PEP is not in itself a reason to refuse service.

7.4 High-risk jurisdictions. Customers from FATF "call for action" jurisdictions are blocked at registration (section 8). Customers linked to FATF "increased monitoring" jurisdictions receive an enhanced review. The Compliance Officer updates the internal list after each FATF plenary statement.

7.5 Refusal and exit. If a review cannot be completed, or the risk exceeds Solo Clash's appetite, the Compliance Officer may refuse or end the relationship. Any funds are then handled under section 9.8. The Compliance Officer also considers whether to report the matter under section 11.

Solo Clash does not knowingly deal with sanctioned persons or restricted jurisdictions. It does not screen names against sanctions lists; it blocks restricted jurisdictions on its own platform and acts on any sanctions concern it becomes aware of.

8.1 Screening by Payment Providers. Solo Clash understands that Paymid, its PSPs, TTS and RiseWorks screen against the sanctions lists that apply to them. Solo Clash does not receive the results and does not rely on them for its own decisions.

8.2 Solo Clash's own controls.

• Registration and access are blocked from restricted jurisdictions using IP geolocation.
• VPN, proxy and Tor connections are detected and flagged.
• Declared country of residence is checked against IP history before a Payout.
• Payouts are made only through RiseWorks, never directly through Solo Clash affiliated accounts.

8.3 Handling a sanctions concern. A concern may arise from public information, something the customer says, a request from an authority, or platform data such as access from a restricted jurisdiction.

1. Stop approving Payouts on all linked accounts.
2. Escalate to the Compliance Officer the same day.
3. If the link is credible: suspend the accounts and consider a report under section 11.
4. If not: record the reason and clear the concern.

Where the link is credible, Solo Clash suspends all the customer's accounts without delay and approves no further Payouts or refunds. It follows any instructions from the authorities and considers a report under section 11. The customer is not told the reason (see section 11.4).

8.4 Restricted jurisdictions. Solo Clash does not accept customers who are resident in, citizens of, or accessing the service from restricted jurisdictions. The restriction logic is derived from the below categorisation:

The list forms part of the Terms and Conditions.

8.5 Circumvention. Using a VPN, proxy, false address or another person's identity to get around restrictions is a serious breach. It results in account closure, forfeiture of pending payouts where lawful, and possible reporting.

Money never moves through Solo Clash's own platform. Challenge fees and refunds go through Paymid and PSPs; Payouts go through RiseWorks. Solo Clash's control is deciding whether a refund or Payout is approved.

9.1 Payment channels. Challenge fees are accepted only through Paymid. Solo Clash does not accept cash, direct bank transfers to its own accounts, or any payment outside Paymid.

9.2 No third-party payments. The Terms and Conditions require the payer and the Payout recipient to be the account holder. Solo Clash cannot see payer or recipient details, so it relies on the customer's confirmation and on its own platform checks. Evidence of third-party funding or receipt leads to account review and may lead to closure.

9.3 Crypto assets. Crypto fees are accepted only where PSPs offers them. Privacy coins are not accepted.

9.4 Payout approval. Solo Clash approves a Payout for release through TTS only when:

1. The trading has passed rule-compliance review under the Terms and Conditions.
2. No open monitoring alert, chargeback or payment dispute exists on the customer's linked accounts.
3. Any enhanced review under section 7 is complete and approved.

RiseWorks then apply their own onboarding and checks before paying the trader. Solo Clash is not told the outcome of those checks.

9.5 Payout routing. Payouts are made only through RiseWorks, to the account holder's own account with them. Solo Clash does not pay traders directly, split Payouts across recipients, or pay through any other route.

9.6 Refunds. Refunds are made through Paymid to the original payment, for no more than the amount paid. Solo Clash does not refund to a different method or outside Paymid.

9.7 Chargebacks. A chargeback on any linked account suspends Payout approvals on all linked accounts pending review.

9.8 Held Payouts. Where Solo Clash has a concern, it does not approve the Payout. The Compliance Officer decides next steps, in line with law and any authority's instructions. Solo Clash is not liable for delays caused by Payment Provider checks, or by complying with this policy.

Solo Clash monitors every customer for the life of the relationship. Automated rules raise alerts; trained staff review them; anything unexplained goes to the Compliance Officer.

10.1 What is monitored. Solo Clash monitors its platform data: account and device links, login and IP patterns, trading patterns across linked accounts, purchase and payout request patterns, changes to account details, failed fee or refund transactions, and chargebacks. Paymid, PSPs, TTS and RiseWorks monitor payments under their own programmes, but share no results with Solo Clash.

10.2 Red flags. Staff should escalate when they see any of these:

10.3 Alert handling.

1. First-line review within 2 business days of the alert.
2. Document the facts, the explanation sought and the outcome.
3. Close the alert with reasons, or escalate to the Compliance Officer using an internal suspicion report.
4. Payouts on the linked accounts stay on hold while an alert is open.

10.4 Link to fraud controls. AML monitoring runs alongside Solo Clash's trading-abuse and fraud detection (for example latency arbitrage, consistency gaming, withdrawal-timing abuse and copy-trading rings). A fraud finding that suggests money is being moved or disguised is treated as a possible AML case.

Any staff member who suspects money laundering, terrorist financing, sanctions evasion or other financial crime must tell the Compliance Officer at once. They must not tell the customer.

11.1 Internal reporting. Staff raise concerns with the Compliance Officer the same business day, using the internal form or the compliance channel. Staff do not investigate further or confront the customer.

11.2 Assessment. The Compliance Officer reviews the facts and decides what to do. Options include clearing the concern, asking the customer for more information, restricting or closing accounts, and reporting externally. The decision and reasons are recorded.

11.3 External reporting. Where the Compliance Officer has reasonable grounds to suspect financial crime, Solo Clash may report the matter to the competent authorities, such as the police or public prosecution in the relevant jurisdiction. It may also inform the payment partners involved. Solo Clash follows any lawful instructions it receives, including instructions to hold funds.

11.4 No tipping-off. Staff must not tell a customer or third party that a concern has been raised, that a report may be made, or that a review is under way. Customer messages about held payouts use neutral wording, for example "your payout is under standard review".

11.5 Protection for reporters. Staff who raise concerns in good faith are protected from disciplinary action. Retaliation against them is a disciplinary offence.

11.6 Requests from authorities. Solo Clash cooperates with lawful requests from law enforcement, courts and other authorities. All requests go to the Compliance Officer, who logs them and responds within the deadline given.

12.1 Record keeping. Solo Clash keeps these records for at least 5 years after the relationship ends or the transaction completes, whichever is later, or longer if an authority asks:

• Account and registration records, and any identification collected under section 6.2.
• Risk ratings, enhanced review files and Compliance Officer approvals.
• Purchase and refund records with Paymid transaction references and status; Payout approvals and any TTS or RiseWorks references; commission records.
• Monitoring alerts, investigations and their outcomes.
• Internal suspicion reports, external reports, Compliance Officer decisions and correspondence with authorities.
• Training records and versions of this policy.

Records are stored securely, access is logged, and they can be produced to authorities promptly. Personal data is processed under the Solo Clash Privacy Policy and applicable data protection law, including the GDPR for EU residents.

12.2 Training. All staff and relevant contractors complete AML/CFT and sanctions training when they join and at least once a year. Risk, payouts and support staff get extra role-specific training on the red flags in section 10. Completion is tracked, and each module ends with a test.

12.3 Staff checks. New staff in compliance, risk, finance and payouts have references and relevant background checked before starting, using available public information.

12.4 Affiliates and partners. Affiliate commissions are paid only through RiseWorks. Before the first commission, Solo Clash collects the affiliate's identity details and, for companies, registration documents. Companies must also give Solo Clash the names of beneficial owners of 25% or more. Commissions go only to accounts in the affiliate's own name. Affiliates may not pay for, or pass funds to, referred traders. Breaches lead to termination and forfeiture of unpaid commissions where lawful.

12.5 Customer obligations and consequences. By using Solo Clash, customers agree to give accurate information and to complete any verification Paymid, PSPs, TTS or RiseWorks require, and to answer Solo Clash's information requests. Where a customer breaches this policy, Solo Clash may, where lawful:

1. Suspend accounts and hold payouts pending review.
2. Refuse or cancel purchases and refund to the original payment method.
3. Close all linked accounts.
4. Withhold payouts obtained in breach of this policy or the Terms and Conditions.
5. Report the matter to the relevant authorities.

12.6 Staff breaches. A staff breach of this policy is a disciplinary matter and may lead to dismissal and referral to authorities.

12.7 Review. The Compliance Officer reviews this policy at least once a year, and sooner after a change in law, a new product or payment method, or a material finding. The Managing Director approves each version.

Compliance questions go to the Compliance Officer at [email protected].