Anti-Money Laundering (AML) Policy

Effective Date: June 4, 2025

DEFINITIONS

AML / Compliance Department

The unit with primary responsibility for the AML program.

Business relationship

A commercial relationship between a Customer and the Organisation.

Customer Due Diligence (CDD)

The process of identifying and verifying a customer's identity and monitoring their transactions.

Money laundering (ML)

The act of concealing the origin of illegally obtained funds.

Politically Exposed Person (PEP)

Natural persons who are or have been entrusted with prominent public functions.

1. SCOPE OF THE POLICY

It is the Organisation's policy to prohibit and prevent any cases of money laundering and terrorist financing. This Policy applies to all employees and aims to ensure compliance with all relevant legislation, including EU Directives and the Anjouan Money Laundering (Prevention) Act.

2. BOARD OF DIRECTORS

The Board of Directors is responsible for ensuring the Organisation complies with its AML obligations, including approving the AML policy, appointing an AML Officer, and ensuring all employees are trained and aware of their responsibilities.

3. ROLE AND RESPONSIBILITIES OF AML OFFICER

The AML Officer is responsible for drafting and monitoring the AML procedures, developing the Customer Acceptance Policy, advising employees, and reporting suspicious transactions to the relevant authorities.

4. RISK-BASED APPROACH

The Organisation directs resources proportionately according to the extent of the ML/TF risks posed. Customers are categorized as low, medium, or high risk based on factors such as jurisdiction, transaction behavior, and PEP status. High-risk customers receive the highest level of scrutiny.

5. CUSTOMER DUE DILIGENCE (CDD) AND VERIFICATION

We apply CDD measures when establishing a business relationship, when there is a suspicion of ML/TF, or when there are doubts about previously obtained data. This includes identifying the customer, verifying their identity with reliable documents, and understanding the purpose of the business relationship.

6. ENHANCED DUE DILIGENCE (EDD) FOR HIGH-RISK CUSTOMERS

Enhanced measures are applied to high-risk customers, including PEPs and customers from high-risk jurisdictions. This includes obtaining additional documentation, verifying source of wealth, and performing more frequent monitoring.

7. SANCTIONS COMPLIANCE

The Organisation has implemented procedures to ensure compliance with international sanctions programs (e.g., from OFAC, EU, UN). This includes automated daily screening of all customers against prevailing sanction lists.

8. RECORD-KEEPING

All records related to CDD, transactions, and internal/external reports are retained for at least five (5) years after the termination of the business relationship, in accordance with legal requirements.

9. EMPLOYEE TRAINING

All relevant employees receive regular training on AML/CTF regulations, KYC best practices, and their personal obligation to identify and report suspicious activity.