ANTI-MONEY LAUNDERING (AML) & KYC POLICY

Effective Date: May 27, 2026

Company: SterHK Limited

Business Registration Number: 80351629

Registered Office: RM 511, 5/F, MING SANG IND BLDG, 19-21 HING YIP STREET, KWUN TONG, HONG KONG

Contact Email: Support@winforge.gg

1.1. SterHK Limited ("Company", "we", "Platform") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance.
1.2. This policy outlines our procedures to prevent our B2C digital platform from being used for money laundering, fraud, or other financial crimes. We strictly adhere to the AML/CTF regulations of Hong Kong and relevant international standards.

2.1. Risk-Based Approach: The Company employs a risk-based approach to verify the identity of our Customers.
2.2. Standard Verification: For standard digital coaching transactions, basic data collection (email, billing details, IP address) is conducted automatically via our secure payment gateway.
2.3. Enhanced Due Diligence (EDD): The Company reserves the right to request additional KYC documentation (such as a government-issued ID, proof of address, or a selfie with ID) under the following circumstances:

Transactions exceeding standard thresholds (e.g., single or cumulative purchases over $1,000).
Suspicious payment patterns, use of high-risk payment methods, or mismatched billing information.

2.4. Refusal to provide requested KYC documents will result in the immediate suspension of the transaction, withholding of funds, and potential account termination.

3.1. All transactions processed through the Platform are monitored in real-time using automated security tools provided by our payment partners.
3.2. We actively monitor for red flags, including but not limited to:

Unusually high transaction volumes from newly registered accounts.
Multiple failed payment attempts using different credit cards.
Requests for refunds to alternative payment methods rather than the original source of funds.
Suspicious activity indicating collusion between a Customer and an Independent Coach to bypass platform security or commit payment fraud.
Customers attempting to bypass standard platform billing or usage.

4.1. Sanctions Compliance: The Company does not conduct business with individuals, entities, or jurisdictions subject to comprehensive sanctions by Hong Kong, the United Nations Security Council, the European Union, or the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC).
4.2. Geographic Restrictions: Users from comprehensively sanctioned jurisdictions are prohibited from accessing the Platform or utilizing our coaching services.
4.3. Politically Exposed Persons (PEPs): Accounts identified as belonging to PEPs will be subject to Enhanced Due Diligence and require senior management approval before transactions are processed.

5.1. In compliance with Hong Kong financial regulations, the Company retains all KYC documentation, transaction logs, and communication records for a minimum period of five (5) years following the termination of the business relationship or the date of the last transaction.
5.2. These records are stored securely and remain strictly confidential, accessible only to authorized compliance personnel or competent legal authorities upon formal request.

6.1. The Company maintains internal procedures for staff and Independent Coaches to report unusual or suspicious behavior.
6.2. If a transaction is deemed highly suspicious or indicative of money laundering, the Company is legally obligated to file a Suspicious Transaction Report (STR) with the relevant financial intelligence units in Hong Kong, without providing prior notice to the User ("tipping-off" prohibition).

7.1. For any questions regarding this AML/KYC Policy, or to submit required verification documents, please contact our compliance team at: Email: Support@winforge.gg