Somnia 백서 전문

n to the SOMI distribution, and not in the capacity as a financial advisor or fiduciary of any person with regard to the distribution of SOMI. **Nature of the Token Documentation:**\ The Token Documentation is a conceptual paper that articulates some of the main design principles and ideas for the creation of a digital token to be known as SOMI. The Token Documentation and the Website are intended for general informational purposes only and do not constitute a prospectus, an offer document, an offer of securities, a solicitation for investment, any offer to sell any product, item, or asset (whether digital or otherwise), or any offer to engage in business with any external individual or entity provided in said documentation. The information herein may not be exhaustive and does not imply any element of, or solicit in any way, a legally-binding or contractual relationship. There is no assurance as to the accuracy or completeness of such information and no representation, warranty or undertaking is or purported to be provided as to the accuracy or completeness of such information. Where the Token Documentation or the Website includes information that has been obtained from third party sources, the Company, the Distributor, their respective affiliates and/or the Somnia team have not independently verified the accuracy or completeness of such information. Further, you acknowledge that the project development roadmap, platform/network functionality are subject to change and that the Token Documentation or the Website may become outdated as a result; and neither the Company nor the Distributor is under any obligation to update or correct this document in connection therewith. **Validity of Token Documentation and Website:**\ Nothing in the Token Documentation or the Website constitutes any offer by the Company, the Distributor, or the Somnia team to sell any SOMI (as defined herein) nor shall it or any part of it nor the fact of its presentation form the basis of, or be relied upon in connection with, any contract or investment decision. Nothing contained in the Token Documentation or the Website is or may be relied upon as a promise, representation or undertaking as to the future performance of Somnia. The agreement between the Distributor (or any third party) and you, in relation to any distribution or transfer of SOMI, is to be governed only by the separate terms and conditions of such agreement. The information set out in the Token Documentation and the Website is for community discussion only and is not legally binding. No person is bound to enter into any contract or binding legal commitment in relation to the acquisition of SOMI, and no digital asset or other form of payment is to be accepted on the basis of the Token Documentation or the Website. The agreement for distribution of SOMI and/or continued holding of SOMI shall be governed by a separate set of Terms and Conditions or Token Distribution Agreement (as the case may be) setting out the terms of such distribution and/or continued holding of SOMI (the Terms and Conditions), which shall be separately provided to you or made available on the Website. The Terms and Conditions must be read together with the Token Documentation. In the event of any inconsistencies between the Terms and Conditions and the Token Documentation or the Website, the Terms and Conditions shall prevail. **Deemed Representations and Warranties:**\ By accessing the Token Documentation or the Website (or any part thereof), you shall be deemed to represent and warrant to the Company, the Distributor, their respective affiliates, and the Somnia team as follows: 1. in any decision to acquire any SOMI, you have not relied and shall not rely on any statement set out in the Token Documentation or the Website; 2. you shall at your own expense ensure compliance with all laws, regulatory requirements and restrictions applicable to you (as the case may be); 3. you acknowledge, understand and agree that SOMI may have no value, there is no guarantee or representation of value or liquidity for SOMI, and SOMI is not an investment product nor is it intended for any speculative investment whatsoever; 4. none of the Company, the Distributor, their respective affiliates, and/or the Somnia team shall be responsible for or liable for the value of SOMI, the transferability and/or liquidity of SOMI and/or the availability of any market for SOMI through third parties or otherwise; and 5. you acknowledge, understand and agree that you are not eligible to participate in the distribution of SOMI if you are a citizen, national, resident (tax or otherwise), domiciliary and/or green card or permanent visa holder of a geographic area or country (i) where it is likely that the distribution of SOMI would be construed as the sale of a security (howsoever named), financial service or investment product and/or (ii) where participation in token distributions is prohibited by applicable law, decree, regulation, treaty, or administrative act (including without limitation the United States of America, Canada, and the People's Republic of China); and to this effect you agree to provide all such identity verification document when requested in order for the relevant checks to be carried out. The Company, the Distributor and the Somnia team do not and do not purport to make, and hereby disclaims, all representations, warranties or undertaking to any entity or person (including without limitation warranties as to the accuracy, completeness, timeliness, or reliability of the contents of the Token Documentation or the Website, or any other materials published by the Company or the Distributor). To the maximum extent permitted by law, the Company, the Distributor, their respective affiliates and service providers shall not be liable for any indirect, special, incidental, consequential or other losses of any kind, in tort, contract or otherwise (including, without limitation, any liability arising from default or negligence on the part of any of them, or any loss of revenue, income or profits, and loss of use or data) arising from the use of the Token Documentation or the Website, or any other materials published, or its contents (including without limitation any errors or omissions) or otherwise arising in connection with the same. Prospective acquirors of SOMI should carefully consider and evaluate all risks and uncertainties (including financial and legal risks and uncertainties) associated with the distribution of SOMI, the Company, the Distributor and the Somnia team. **SOMI Token:**\ SOMI are designed to be utilised, and that is the goal of the SOMI distribution. In particular, it is highlighted that SOMI: 1. does not have any tangible or physical manifestation, and does not have any intrinsic value/pricing (nor does any person make any representation or give any commitment as to its value); 2. is non-refundable, not redeemable for any assets of any entity or organisation, and cannot be exchanged for cash (or its equivalent value in any other digital asset) or any payment obligation by the Company, the Distributor or any of their respective affiliates; 3. does not represent or confer on the token holder any right of any form with respect to the Company, the Distributor (or any of their respective affiliates), or their revenues or assets, including without limitation any right to receive future dividends, revenue, shares, ownership right or stake, share or security, any voting, distribution, redemption, liquidation, proprietary (including all forms of intellectual property or licence rights), right to receive accounts, financial statements or other financial data, the right to requisition or participate in shareholder meetings, the right to nominate a director, or other financial or legal rights or equivalent rights, or intellectual property rights or any other form of participation in or relating to Somnia, the Company, the Distributor and/or their service providers; 4. is not intended to represent any rights under a contract for differences or under any other contract the purpose or intended purpose of which is to secure a profit or avoid a loss; 5. is not intended to be a representation of money (including electronic money), payment instrument, security, commodity, bond, debt instrument, unit in a collective investment or managed investment scheme or any other kind of financial instrument or investment; 6. is not a loan to the Company, the Distributor or any of their respective affiliates, is not intended to represent a debt owed by the Company, the Distributor or any of their respective affiliates, and there is no expectation of profit nor interest payment; and 7. does not provide the token holder with any ownership or other interest in the Company, the Distributor or any of their respective affiliates. Notwithstanding the SOMI distribution, users have no economic or legal right over or beneficial interest in the assets of the Company, the Distributor, or any of their affiliates after the token distribution. For the avoidance of doubt, neither the Company nor the Distributor deals in, or is in the business of buying or selling any virtual asset or digital payment token (including SOMI). Any sale or distribution of tokens would be performed during a restricted initial period solely for the purpose of obtaining project development funds, raising market/brand awareness, as well as community building and social engagement; this is not conducted with any element of repetitiveness or regularity which would constitute a business. To the extent a secondary market or exchange for trading SOMI does develop, it would be run and operated wholly independently of the Company, the Distributor, the distribution of SOMI and Somnia. Neither the Company nor the Distributor will create such secondary markets nor will either entity act as an exchange for SOMI. **Informational purposes only:**\ The information set out herein is only conceptual, and describes the future development goals for Somnia to be developed. In particular, the project roadmap in the Token Documentation is being shared in order to outline some of the plans of the Somnia team, and is provided solely for INFORMATIONAL PURPOSES and does not constitute any binding commitment. Please do not rely on this information in deciding whether to participate in the token distribution because ultimately, the development, release, and timing of any products, features or functionality remains at the sole discretion of the Company, the Distributor or their respective affiliates, and is subject to change. Further, the Token Documentation or the Website may be amended or replaced from time to time. There are no obligations to update the Token Documentation or the Website, or to provide recipients with access to any information beyond what is provided herein. **Regulatory approval:**\ No regulatory authority has examined or approved, whether formally or informally, any of the information set out in the Token Documentation or the Website. No such action or assurance has been or will be taken under the laws, regulatory requirements or rules of any jurisdiction. The publication, distribution or dissemination of the Token Documentation or the Website does not imply that the applicable laws, regulatory requirements or rules have been complied with. **Cautionary Note on forward-looking statements:**\ All statements contained herein, statements made in press releases or in any place accessible by the public and oral statements that may be made by the Company, the Distributor and/or the Somnia team, may constitute forward-looking statements (including statements regarding the intent, belief or current expectations with respect to market conditions, business strategy and plans, financial condition, specific provisions and risk management practices). You are cautioned not to place undue reliance on these forward-looking statements given that these statements involve known and unknown risks, uncertainties and other factors that may cause the actual future results to be materially different from that described by such forward-looking statements, and no independent third party has reviewed the reasonableness of any such statements or assumptions. These forward-looking statements are applicable only as of the date indicated in the Token Documentation, and the Company, the Distributor as well as the Somnia team expressly disclaim any responsibility (whether express or implied) to release any revisions to these forward-looking statements to reflect events after such date. **References to companies and platforms:**\ The use of any company and/or platform names or trademarks herein (save for those which relate to the Company, the Distributor or their respective affiliates) does not imply any affiliation with, or endorsement by, any third party. References in the Token Documentation or the Website to specific companies and platforms are for illustrative purposes only. **English language:**\ The Token Documentation and the Website may be translated into a language other than English for reference purpose only and in the event of conflict or ambiguity between the English language version and translated versions of the Token Documentation or the Website, the English language versions shall prevail. You acknowledge that you have read and understood the English language version of the Token Documentation and the Website. **No Distribution:**\ No part of the Token Documentation or the Website is to be copied, reproduced, distributed or disseminated in any way without the prior written consent of the Company or the Distributor. By attending any presentation on this Token Documentation or by accepting any hard or soft copy of the Token Documentation, you agree to be bound by the foregoing limitations. # AML Compliance Anti-Money Laundering (AML) Policy **Our Commitment:**\ Somnia ServiceCo. Ltd., Somnia TokenCo. Ltd., and Somnia NetworkCo. Ltd. (collectively, the "Companies") are committed to maintaining the highest standards of compliance with anti-money laundering (AML), counter-terrorism financing (CFT), and sanctions laws. We implement robust policies and procedures to prevent our services from being misused for illicit purposes. **Policy Overview:**\ As companies incorporated in the British Virgin Islands, we voluntarily adopt comprehensive AML/CFT compliance measures as a matter of best practice, implementing policies based on international standards and regulatory frameworks. *** ### KEY PRINCIPLES **Risk-Based Approach:**\ We employ a comprehensive risk-based approach to identify, assess, and mitigate money laundering, terrorist financing, and proliferation financing risks across our operations, including: * Customer due diligence assessments * Geographic risk evaluation * Product and service risk analysis * Transaction monitoring \ **Know Your Customer (KYC):**\ We conduct thorough customer identification and verification procedures for all clients, including: * Identity verification * Beneficial ownership identification * Sanctions screening * Enhanced due diligence for high-risk customers **Ongoing Monitoring:**\ We maintain continuous monitoring of business relationships and transactions to: * Detect unusual or suspicious activities * Ensure consistency with customer profiles * Update customer information regularly * Screen against sanctions lists ### COMPLIANCE FRAMEWORK **Prohibited Activities:**\ We do not engage in business relationships or transactions with: * Individuals or entities on sanctions lists * Politically Exposed Persons (PEPs) without enhanced due diligence * Customers from high-risk jurisdictions without appropriate controls * Any party involved in money laundering, terrorist financing, or other illicit activities **Enhanced Due Diligence:**\ We apply enhanced due diligence measures for: * High-risk jurisdictions (including but not limited to Burma, Iran, North Korea) * Politically Exposed Persons and their associates * Complex corporate structures * Unusual transaction patterns **Record Keeping:**\ We maintain comprehensive records of: * Customer identification and verification documents * Transaction records * Compliance documentation * Suspicious activity reports All records are retained for a minimum of five years in secure, confidential systems. ### REPORTING **Suspicious Activity:**\ We have established procedures for identifying and reporting suspicious activities to relevant authorities. All employees are trained to recognize red flags and report concerns through appropriate channels. **Regulatory Cooperation:**\ We maintain full cooperation with regulatory authorities and law enforcement agencies, responding promptly to information requests and regulatory inquiries. ### TRAINING AND AWARENESS All relevant personnel receive regular AML/CFT training to ensure: * Understanding of legal obligations * Recognition of suspicious activities * Proper implementation of compliance procedures * Awareness of emerging risks and threats ### CONTACT For compliance-related inquiries or to report suspicious activities: **Money Laundering Reporting Officer (MLRO):**\ Campbells Regulatory Services Limited\ Email: <Compliance_Services@campbellslegal.com> ### REGULATORY FRAMEWORK Our compliance program is designed to meet the requirements of applicable laws and regulations, including: * BVI Anti-Money Laundering Regulations * BVI Anti-Money Laundering and Terrorist Financing Code of Practice * International sanctions regimes * FATF Recommendations *** *We regularly review and update our AML/CFT policies and procedures to ensure they remain effective and compliant with evolving regulatory requirements and industry best practices.* *This policy is effective as of the date of publication and is subject to periodic review and updates. For the most current version, please visit this page from time to time.* # Airdrop Policy This Airdrop Policy ("Policy") governs the distribution of SOMI tokens ("Tokens") by Somnia TokenCo Ltd. ("Company," "we," "us," or "our") to eligible participants ("Participants", “you”, “your”) through our token airdrop program ("Airdrop"). By participating in the Airdrop, you agree to be bound by this Policy and our Terms of Service. *** <h3 align="center"><strong>DISCLAIMER: THIS POLICY GOVERNS YOUR PARTICIPATION IN THE AIRDROP AND CONSTITUTES A LEGALLY BINDING AGREEMENT BETWEEN YOU AND US. PLEASE READ THIS POLICY CAREFULLY. YOUR PARTICIPATION IN THE AIRDROP SHALL CONSTITUTE YOUR ACCEPTANCE TO THIS AIRDROP POLICY IN ITS ENTIRETY.</strong></h3> *** **By participating in the Airdrop, you acknowledge that:** 1. Somnia assumes no responsibility for your Participation and the consequences thereof; 2. Somnia does not offer any professional advice or recommendations regarding the Airdrop or tokens. The information provided is for informational purpose only, nothing in this Policy shall be construed as being professional advice; 3. This Policy does not establish any fiduciary relationship between Somnia and Participants. Somnia disclaims any fiduciary duty or liability to the maximum extent permitted by law; 4. You are making an independent decision in respect of your participation and your participation is at your own risk; and 5. It is your responsibility to seek professional legal, tax or other advice before participating in the Airdrop. ### **ELIGIBILITY** **Who can participate:** 1. Participants must be at least 18 years of age and not a Prohibited Person. A “Prohibited Person” is any person or entity that is (a) the subject of any economic or trade sanctions administered or enforced by any governmental authority, including any person designated on any list of prohibited or restricted parties by any governmental authority, such as the European Union (“EU”) Consolidated List of Persons, the United Kingdom (“UK”) Consolidated List