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Legal

AML/KYC & SANCTIONS POLICY

A public summary of the anti-money laundering, identity verification and sanctions procedures that may apply to certain BROOKMI services.

01Purpose

This is a public policy summary. It describes, in general terms, how MOTIRATECH HOLDINGS INC., operating the BROOKMI brand, may apply anti-money laundering (AML), know-your-customer (KYC) and sanctions compliance procedures.

It is not the company's internal compliance program and does not disclose internal procedures, thresholds or controls.

02Risk-Based Approach

BROOKMI may apply risk-based AML/KYC and sanctions compliance procedures where applicable, depending on the type of service, the transaction and legal requirements.

Not every BROOKMI service is a regulated money services activity. General website use, reading information or submitting an energy project inquiry does not by itself involve money services.

03Information You May Be Asked to Provide

Depending on the service and legal requirements, users may be asked for:

  • identity verification;
  • beneficial ownership information (for businesses);
  • source-of-funds information;
  • information needed for sanctions screening;
  • information relating to transaction monitoring; and
  • additional compliance information where reasonably required.

04Refusal, Delay or Suspension

BROOKMI may refuse, delay, restrict or suspend a transaction or account where required by applicable law, regulatory requirements, sanctions obligations, fraud prevention or security considerations, or where requested information is not provided.

BROOKMI may not be able to explain the specific reason for a compliance decision where disclosure is restricted by law.

05Sanctions

BROOKMI services are not intended for persons or entities subject to applicable sanctions, or for transactions involving sanctioned jurisdictions where prohibited by law.

06Third-Party Providers

Certain payment, fiat conversion, identity verification or digital asset acquisition services may be provided by independent third-party service providers and may be subject to their own terms, eligibility requirements, fees and compliance procedures. Such providers are not operated by BROOKMI, and their availability does not indicate approval of BROOKMI by any provider or regulator.

Identity verification and screening performed by a third-party provider is subject to that provider's own terms and privacy practices. See the Privacy Policy for how personal information is handled.

07Regulatory Status

MOTIRATECH HOLDINGS INC. submitted its pre-registration request to FINTRAC (Financial Transactions and Reports Analysis Centre of Canada) on September 18, 2026, in connection with its anticipated money services business activities. The company is currently completing the applicable regulatory process.

MOTIRATECH HOLDINGS INC. does not represent itself as a FINTRAC-registered money services business until the applicable registration has been approved. No FINTRAC registration number has been issued as of the date of this notice.

08Contact

Compliance questions may be sent to hello@brookmi.com or +1 587-218-8888.