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Cookie Policy Horus Media Limited Last Updated: 19 May 2026 Cookie & Tracking Framework 10. SANCTIONS, ANTI-MONEY-LAUNDERING, KNOW-YOUR-CUSTOMER AND ANTI-BRIBERY 10.1 Sanctions screening. The Customer represents and warrants that neither it, nor any of its directors, officers, beneficial owners, ultimate beneficial owners (UBOs), shareholders holding 25% or more, employees or agents, is: (a) listed on any sanctions list maintained by the United Nations Security Council, the European Union (EU Consolidated List), the United Kingdom (HM Treasury / OFSI Consolidated List), the United States (OFAC SDN List), Hong Kong, Switzerland (SECO) or any other competent authority; (b) located in, ordinarily resident in, or controlled from, a country or region subject to comprehensive territorial sanctions (currently including, without limitation, Cuba, Iran, North Korea, Syria, the Crimea region, and the so-called Donetsk and Luhansk regions); (c) a Politically Exposed Person (PEP), family member of a PEP or close associate of a PEP, unless expressly disclosed to Horus Media in writing. The Customer authorises Horus Media and Airwallex to conduct sanctions and PEP screening on an initial and ongoing basis, including by consulting reputable third-party databases. 10.2 Anti-money-laundering and counter-terrorism financing. The Customer undertakes to comply with all applicable AML/CTF laws, including but not limited to: (a) the Hong Kong Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) and related HKMA / Customs & Excise guidelines; (b) EU Directives 2015/849 (4AMLD), 2018/843 (5AMLD), Regulation (EU) 2023/1113 (Travel Rule) and forthcoming EU AML Regulation, as transposed and applicable; (c) the UK Proceeds of Crime Act 2002, the Terrorism Act 2000 and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017); (d) the FATF Recommendations, including Recommendation 16 (Travel Rule). 10.3 Anti-bribery and anti-corruption. The Customer represents that it has not, and will not, directly or indirectly, offer, promise, give, request or accept any undue advantage, kickback, facilitation payment or bribe in connection with the Services, and complies with: (a) the Hong Kong Prevention of Bribery Ordinance (Cap. 201); (b) the UK Bribery Act 2010; (c) the US Foreign Corrupt Practices Act (FCPA); (d) any equivalent applicable anti-bribery laws. 10.4 KYC / KYB documentation. The Customer agrees to provide, upon request by Horus Media or Airwallex, accurate and up-to-date documentation and information necessary for customer due diligence, including but not limited to: (a) certificate of incorporation, business registration, articles of association, register of shareholders and directors; (b) identity documents (passport, national ID) and proof of address of directors, authorised signatories, beneficial owners and UBOs; (c) ownership structure / corporate chart showing UBOs; (d) financial statements, bank statements, tax returns (where relevant); (e) source of funds and, for high-value transactions, source of wealth documentation; (f) description of the underlying business activity, expected transaction volumes and counterparties; (g) regulatory licences, permits or authorisations applicable to the Customer's activity; (h) tax residency certificates and CRS / FATCA self-certifications, where applicable. Failure to provide such documentation within a reasonable timeframe may result in the refusal to onboard the Customer or the suspension or termination of the Services. 10.5 Enhanced Due Diligence (EDD). Horus Media and Airwallex may apply Enhanced Due Diligence measures where: (a) the Customer is a PEP or linked to a PEP; (b) the Customer is established in, or processes transactions to/from, a high-risk third country listed by the EU, the FATF or other competent authorities; (c) the transaction pattern is unusual, complex or lacks an apparent economic or lawful purpose; (d) the Customer operates in a high-risk industry under Section 4.2 of the Acceptable Use Policy. 10.6 Travel Rule (originator/beneficiary information). For cross-border payment transactions, the Customer acknowledges that the originator and beneficiary information (name, account number, address or unique identifier) may be transmitted between payment service providers in accordance with FATF Recommendation 16, Regulation (EU) 2023/1113 and equivalent rules. 10.7 Suspicious activity. If Horus Media has reasonable grounds to suspect that a transaction or activity is related to money laundering, terrorism financing, sanctions evasion or any other financial crime, we may, without prior notice and without incurring any liability: (a) suspend or terminate the Services; (b) freeze pending transactions and funds, to the extent permitted by law; (c) file a Suspicious Transaction Report (STR) / Suspicious Activity Report (SAR) with the competent Financial Intelligence Unit (Joint Financial Intelligence Unit in Hong Kong, NCA in the UK, national FIUs in the EU); (d) cooperate with law-enforcement, regulators and Airwallex. The Customer acknowledges that, under applicable AML laws (including "tipping-off" prohibitions in HK Cap. 615 s.25A and UK POCA s.333A), Horus Media may be prohibited from disclosing the reason for the suspension, freeze or termination. 10.8 Record-keeping. The Customer undertakes to retain, for at least five (5) years (or longer where required by applicable law), all records, invoices, contracts and supporting documents related to its transactions with Horus Media and its end-customers, and to make such records available upon reasonable request by Horus Media, Airwallex or any competent authority. 10.9 Notification of material changes. The Customer must promptly (and in any case within fifteen (15) days) notify Horus Media in writing at [email protected] of any material change concerning: (a) ownership, control or beneficial ownership structure; (b) directors, officers or authorised signatories; (c) registered office, principal place of business or jurisdiction; (d) nature, scope or scale of the Customer's business activity; (e) any investigation, sanction, prosecution or regulatory action against the Customer or its key personnel; (f) any insolvency, bankruptcy, restructuring or change of control proceedings. 10.10 No waiver of legal duties. Nothing in this Section 10 shall be construed as a waiver of, or limitation on, the legal obligations of Horus Media, Airwallex or the Customer under applicable AML, CTF, sanctions or anti-bribery laws. 11. SUBSCRIPTIONS AND RECURRING PAYMENTS 11.1 Authorisation. By subscribing to a recurring Service, the Customer expressly authorises Horus Media, through Airwallex, to charge the selected payment method at each billing cycle (e.g. monthly, annually) until the subscription is cancelled. 11.2 Cancellation. The Customer may cancel a subscription at any time by writing to [email protected] or, where available, through the user account. Cancellation takes effect at the end of the current billing period; the Customer retains access until then. 11.3 Failed payments. If a recurring payment fails, we may retry the charge and/or suspend the Services until payment is regularised. We will notify the Customer in writing. 12. INTELLECTUAL PROPERTY 12.1 Horus Media IP. All trademarks, logos, software, source code, algorithms, designs, methodologies, frameworks, libraries, documentation, course materials, e-books and other content related to the Services are and remain the exclusive property of Horus Media or its licensors and are protected by applicable intellectual-property laws. Nothing in these Terms transfers ownership of any such intellectual property to the Customer. 12.2 Third-party trademarks. All third-party trademarks referenced in the Services (e.g. Airwallex, Meta, Google, Telegram, OpenAI) are the property of their respective owners. Their mention does not imply endorsement, sponsorship or partnership unless expressly stated. 12.3 Licence to use. Subject to full payment of the Fees and compliance with these Terms, Horus Media grants the Customer a personal, limited, revocable, non-exclusive, non-transferable and non-sublicensable licence to access and use the Services and the Digital Content for the Customer's internal business or personal use, as applicable, for the duration of the contract. 12.4 Custom Deliverables. Unless otherwise agreed in writing in the SOW, ownership of bespoke Deliverables (custom code, custom design, custom content specifically produced for the Customer) is transferred to the Customer upon full payment of the Fees, EXCEPT for: (a) pre-existing materials, libraries, frameworks, tools and know-how owned by Horus Media or by third parties, on which the Customer receives a perpetual, worldwide, royalty-free, non-exclusive licence solely for the use and operation of the Deliverable; (b) generic methodologies, ideas, concepts, techniques and skills, which remain freely available for Horus Media's future use; (c) open-source components, which remain governed by their respective licences. 12.5 Licence restrictions. The Customer shall NOT: (a) copy, reproduce, modify, adapt, translate or create derivative works of the Services or Digital Content, except as expressly permitted; (b) resell, rent, sublicense or commercially exploit the Services; (c) reverse-engineer, decompile or disassemble any software, except to the extent expressly permitted by mandatory law; (d) remove copyright or proprietary notices; (e) share access credentials with unauthorised third parties; (f) use the Digital Content for the training of AI/ML models without our prior written consent. 12.6 Portfolio rights. Unless the Customer requests confidentiality in writing within thirty (30) days of project completion, Horus Media may publicly reference the project (Customer's name, logo, screenshots, high-level description) for portfolio, marketing and reference purposes. 12.7 Customer content licence. By submitting content to Horus Media (briefs, materials, logos, copy, datasets), the Customer grants Horus Media a worldwide, royalty-free, non-exclusive licence to use, store, reproduce and process such content solely for the purpose of providing the Services. 12.8 IP infringement warranty. The Customer warrants that the content and materials it provides do not infringe any third-party rights and shall indemnify Horus Media against any related claim.