Effective Date: 30 June 2026 · Version: 1.0 · Approved by: Chief Executive Officer (CE
1. Purpose & Scope. This Policy describes how Pinex Software Solutions L.L.C-FZ ("Pinex", "the Company") — a company
established under the laws of the United Arab Emirates, registered office at Meydan Grandstand, 6th Floor, Meydan Road, Nad
Al Sheba, Dubai, UAE, License No. 2643553.01 — identifies and verifies its customers and prevents its services from being
used by restricted or sanctioned persons. The Company provides access to simulated trading environments and
educational / evaluation services only; it does not offer trading in real financial instruments. This Policy applies to all
customers, and the Company applies its AML/KYC measures in line with the applicable UAE legal framework and the
sanctions programs of the UN, EU, UK (OFSI) and US (OFA
2. KYC — when. Identity verification is mandatory and is carried out at onboarding, before the customer is granted access to
the Company's paid services or before any payment is processed. No service is provided until the customer's identity has
been successfully verified.
3. KYC — data & verification. For each customer the Company collects: full name, date of birth, nationality and country of
residence; a copy of a valid government-issued photographic identity document (passport, national identity card or driver's
licence); and a live facial image (selfie / liveness check). The Company does not rely on self-declared data alone. Verification
covers: (a) document authenticity — the ID/passport is checked for authenticity, validity and tampering; (b) biometric /
liveness — the live facial image is matched against the photo on the document to confirm the person is the genuine holder
and physically present; (c) jurisdiction check against the prohibited list in Section 5. A customer is approved only when all
checks pass; otherwise the customer is rejected.
4. KYC provider. Identity verification is performed through the Company's KYC / identity-verification provider, Veriff, which
carries out the government-issued document verification and biometric liveness/face-match described above. The Company
retains the verification results and audit trail and remains responsible for the onboarding decision.
5. Restricted jurisdictions & sanctions. The Company does not onboard or provide services to customers who are nationals
of, resident in, or located in a Restricted Jurisdiction (this applies both to the jurisdiction and to its citizens), nor to any person
subject to applicable UN, EU, UK or US sanctions. Restricted Jurisdictions include, at a minimum: Iran; North Korea (DPRK);
Myanmar (Burma); Russian Federation; Belarus; and the occupied territories of Ukraine — namely Crimea and the
affected parts of the Donetsk, Luhansk, Zaporizhzhia and Kherson regions. This list is not exhaustive and is updated
when relevant sanctions are introduced or amended.
6. Record-keeping. The Company retains the KYC records and verification results for each customer for a minimum of five (5)
years after the end of the business relationship, in line with applicable UAE requirements, and makes them available to the
competent authorities upon lawful request.
7. Responsibility. The CEO and Founders hold overall responsibility for the Company's AML/KYC compliance, approve this
Policy, and are the point of contact for the competent authorities. The Policy is reviewed when there is a material change in
applicable law, sanctions or the Company's services