KYC & AML

The issuer has adopted rigorous KYC procedures to verify the identity of every applicant, and the beneficial owner (where applicable) that has expressed interest in acquiring Diagon and only those contributors which have successfully identified themselves in the KYC procedure, to the Issuer's satisfaction, have been successful in participating in the Diagon Private Placement. Strict compliance with KYC procedures protects the contributors and the Issuer from criminal elements such as money laundering activities and terrorism financing.

The KYC procedures adopted were based on current market practices and in accordance with all applicable Maltese and EU legislation The Issuer recognizes the importance of preventing money laundering and terrorism financing therefore AML and counter financing of terrorism procedures have been implemented in accordance with applicable legislation, notably the Prevention of Money Laundering Act (Chapter 373 of the Laws of Malta) including any rules and regulations enacted thereunder. The Issuer particularly requested the identification of any politically exposed persons (“PEPs”), an individual who is or who has been entrusted with prominent public functions, and immediate family members, or persons known to close associates of such persons.

Know Your Customer (KYC) and Anti-Money Laundering (AML) & Counter Financing of Terrorism Procedures: The policies and procedures implemented by the Issuer in this respect are based on contributor’s identification and contributor’s identity verification on the basis of the following sources: Documentation provided by the contributors. Information about the contributors obtained from reliable and independent sources. In particular, the Issuer has and shall not conduct business with the following risky persons: Those refusing to provide the Issuer with required information or documentation. Entities whose shareholder/control structure cannot be determined. Those individuals that are included on any official sanction lists.

Individuals indicating possible involvement in criminal activities based on available information. Those individuals with business where activity, source of funds or source of wealth cannot be reasonably verified. An appropriate record of received documentation and information, copies or recommendations are retained by the Issuer for the legally established time period as per applicable laws, including AML legislation and data protection laws including General Data Protection Regulation.