These documents are published in English only.以下文件僅以英文發布。

AML / KYC Policy

Last updated: 6 September 2026

1. Statement

Dynvora Global Technology Limited ("AnyItem") is committed to preventing the use of its services for money laundering, terrorist financing, sanctions evasion, or any other financial crime.

AnyItem operates as a distribution and servicing partner. Cards are issued by licensed financial institutions. Customer due diligence is performed to standards set by the issuing institution and by applicable law, and the issuing institution retains ultimate responsibility for the regulated aspects of the relationship.

This Policy is aligned with the Financial Action Task Force (FATF) Recommendations and with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) of Hong Kong.

2. Scope

This Policy applies to all customers, all products distributed through the Platform, and all personnel and contractors of AnyItem.

3. Customer due diligence

No card is issued and no account is activated before customer due diligence is completed. Standard due diligence requires:

• full legal name, date of birth and nationality;
• residential address, supported by acceptable documentary evidence;
• a valid government-issued photographic identity document;
• a liveness check confirming the applicant is the document holder;
• confirmation of country of residence.

Enhanced due diligence is applied where the customer is a politically exposed person or a close associate of one, is resident in or connected to a higher-risk jurisdiction, presents an unusual transaction profile, or where the source of funds is unclear. Enhanced due diligence includes documented enquiry into source of funds and source of wealth, and approval at a senior level.

We do not open accounts on an anonymous basis, under a fictitious name, or for any person who is unwilling or unable to complete verification.

4. Sanctions and watchlist screening

All applicants are screened at onboarding and on an ongoing basis against United Nations consolidated sanctions lists, other applicable sanctions lists, politically exposed person databases and adverse media sources. A positive match results in suspension pending review. Confirmed matches result in refusal or termination, and are reported where required.

5. Restricted jurisdictions

Services are not offered to residents of, citizens of, or persons located in the mainland of the People's Republic of China; the United States of America or any of its territories; any jurisdiction subject to comprehensive sanctions administered by the United Nations, the United States, the United Kingdom or the European Union; and any jurisdiction we designate as restricted from time to time. Services are currently offered in Hong Kong SAR, Taiwan and Malaysia only.

Attempts to circumvent these restrictions — including through the use of VPNs, proxies, or false residency information — result in immediate termination.

6. Ongoing monitoring

Transactions are monitored on an ongoing basis using automated screening tools provided by a third-party risk service provider. Monitoring covers, among other indicators:

• transaction velocity and value outside the customer's established profile;
• structuring patterns designed to fall below reporting thresholds;
• funding from or spending with high-risk merchant categories or counterparties;
• geographic inconsistency between stated residence and transaction origin;
• indicators of third-party use of an account.

Alerts are reviewed by trained personnel. Automated screening supports, but does not replace, human judgement. Customer records are subject to periodic review, with frequency determined by risk rating.

7. Source of funds

Where funding originates from virtual assets, we apply the additional controls required by applicable law, including analytics screening of the originating address against known illicit-activity clusters. Funds identified as originating from sanctioned entities, darknet markets, mixing services, or known theft or fraud proceeds are refused, and the matter is escalated in accordance with clause 8.

8. Reporting

Where a transaction or customer gives rise to knowledge or suspicion of money laundering or terrorist financing, the matter is escalated to our Compliance Officer and, where required, reported to the relevant financial intelligence unit and to the issuing institution.

Customers are not informed that a report has been made. Tipping off is prohibited by law and by this Policy.

9. Record keeping

Identification records, transaction records and internal escalation records are retained for seven years following the end of the customer relationship, and made available to regulators and law enforcement on lawful request.

10. Governance and training

Our Compliance Officer is responsible for this Policy and for its implementation. All personnel with customer-facing or transaction-handling responsibilities receive AML / CFT training at onboarding and annually thereafter. This Policy is reviewed at least annually and on any material change of law, product or risk profile.

11. Contact

Compliance enquiries: info@anyitem.cards.

This document has been prepared in English. Where a translation is provided for convenience, the English version prevails in the event of any discrepancy. Questions may be sent to info@anyitem.cards.