Anti-money Laundering Measures-Tyfon Art Mall-Tyfon Cultural Art Comprehensive Service Platform

Anti-money laundering measures

Our internal controls and risk management systems are designed to cover procedures and measures against money laundering. We have implemented anti-money laundering policies and procedures that provide guidance on preventing and detecting money laundering and ensuring compliance with all relevant legal and regulatory requirements (the "Anti-Money Laundering Policy"). The board of directors reviews and updates the anti-money laundering policy every year as necessary to ensure that it is consistent with the Group's financial reporting objectives and complies with relevant anti-money laundering legal and regulatory requirements. We require our employees to strictly comply with our internal policies on anti-money laundering and all applicable laws and regulations.

The main steps and measures set out in the anti-money laundering policy to prevent and detect money laundering include:

A

We have established a "Know Your Customer" due diligence database to record our customers' names, ID numbers, mailing addresses and contact information;
B
We keep all transaction records for 5 years from the completion of the transaction for monitoring purposes, including daily transaction records, receipts, copies of checks, payments in the account book and written communications from the seller;
C
We perform regular post-sale screening and monitoring procedures and investigate where the following indicate possible money laundering activity:
(i) The number of successful transactions between the same buyer and seller within a month exceeds three times;

(ii) The relevant transactions are only between specific sellers and buyers or between a small number of sellers and buyers;

(iii) The cumulative monthly transactions exceed RMB 1 million; or (iv) There are any other suspicious transaction indicators;
D
We provide a reporting mechanism that allows employees to report any malfeasance in the Group to our board of directors and audit committee under confidential conditions, and arrange detailed investigation procedures;
E
We will report suspicious transactions and/or sellers or buyers to the relevant competent authorities or investigative authorities when required to do so in accordance with applicable anti-money laundering laws and regulations;
F
If it is determined that there may be money laundering, misconduct or illegal conduct and/or attempts to conceal money laundering activities by the seller and/or buyer, the board of directors shall consult with legal counsel and determine as soon as practicable what should be done Whether to refer the relevant activities to the relevant competent authorities or investigating agencies for next steps
G
We will let the board of directors and audit committee regularly supervise and review the implementation and effectiveness of the policy.

江苏泰丰文化传播有限公司

Anti-money laundering measures