Required for: all applicants, for any role.

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  CCPE AML Policy & Procedures
  *** PLACEHOLDER — FINAL DOCUMENT PENDING ***
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1. PURPOSE
   The Exchange maintains an Anti-Money-Laundering (AML) program reasonably designed to detect
   and prevent money laundering and terrorist financing.

2. CUSTOMER IDENTIFICATION (KYC)
   Each applicant must provide identifying information and documentation for the firm and its
   authorized signer, including government identification and a completed IRS Form W-9.

3. SANCTIONS SCREENING
   The Exchange screens applicants against the U.S. Treasury OFAC Specially Designated
   Nationals (SDN) list. Potential matches are adjudicated before approval.

4. ONGOING MONITORING
   The Exchange monitors activity for red flags and may request additional information at any
   time.

5. RECORDKEEPING
   Records are retained in accordance with applicable law.

(This is placeholder text describing the intended scope only. The final, authoritative AML
Policy & Procedures will replace this document.)