SUVYD B.V.

Registered under the laws of Curacao with registration number 164492 and registered address at Abraham Mendez Chumaceiro Boulevard 03, P.O. Box 4750, Curacao.

Anti - Money Laundering & Terrorist Financing Manual

dated 07 September, 2025

(Risk Management and Procedures Manual)

Payment Processing Services

and

Money Transmission Services

GENERAL DEFINITIONS

For the purposes of this Manual, unless the context shall prescribe otherwise:

“Beneficial Owner” means an individual or individual who ultimately owns or controls the Client and / or an individual on whose behalf the operation or activity is carried out.

“Business Relationship” means business, professional or commercial relations that are related to the professional activities of the Company.

“Client” means an individual who aims to establish a business relationship or making a transaction with the Company. Counterparties are also treated as Clients only when the Company is executing a Client order by entering into a payment processing/ money transmission transaction directly with the Counterparty.

“Company” means SUVYD B.V. which is incorporated under the laws of Curacao with registration number 164492 and registered address at Abraham Mendez Chumaceiro Boulevard 03, P.O. Box 4750, Curacao.

“FIU/MOT” or “FINANCIAL INTELLIGENCE UNIT” the central national agency responsible for obtaining, requesting, analyzing and / or disseminating financial information to the competent authorities, notably with regard to suspected crimes and the potential financing of terrorism. The FIU's mandate is backed up by national law or regulations. Meldpunt Ongebruikelijke Transacties ("MOT") is a Dutch translation of the Financial Intelligence Unit.

“Regulator” - Central Bank of Curacao and Sint Maarten.

“Payment Processing and Money Transmission and Ancillary Services” means the processing of payments and the transfer of money and ancillary services in accordance with the provisions of the Law for which the Company is licensed to provide by the Regulator.

“Manual” means the Company’s Risk Management & Procedures Manual (this Manual), according to the Law and Regulations.

“Money Laundering and Terrorist Financing” - Central Bank of Curacao and Sint Maarten in its “Provisions and Guidelines on the Detection and Deterrence of Money Laundering and Terrorist Financing for Company (Trust) Service Providers” as of September 2013 (Hereinafter referred to “Provisions of Central Bank ”)in article I.1. defines MONEY LAUNDERING as an attempt to conceal or disguise the nature, location, source, ownership, or control of illegally obtained money. In practice money laundering covers all procedures to change the identity of illegally obtained funds (including cash) so that it appears to have originated from a legitimate source.

All money laundering has three common factors:

1) criminals need to conceal the true ownership and origin of the money;

2) they need to control the money;

3) they need to change the form of the money.

One transaction can be a part of a sophisticated web of complex transactions illustrated below.

To detect a money laundering it is important to check where the cash first enters the financial system.

There are three main stages of money laundering during which the transactions can be involved in criminal activity.

1) Placement: During the first stage of this process the illegal money can enter into the financial system e.g. through deposits in a bank account. Illegal proceeds are easier to detect at the placement stage, when the physical currency enters the financial system.

2) Layering: Illicit proceeds trying to be anonymous and be separated from their source by creating some layers of financial transactions.

3) Integration: If the previous stage has gone successfully, the derived illegal wealth and income proceeds into the economy and all this money are used as normal business funds.

and

TERRORIST FINANCING as an institution that carries out a transaction, knowing that the relevant funds or property belong to or are controlled by terrorists or terrorist organizations, or that the transaction is connected or can be used in terrorist activities, commits a criminal offense. Such an offense may exist regardless of whether the assets involved in the transaction were proceeds of crime or were obtained as a result of legitimate activities, but were intended to be used in support of terrorism.

“Occasional Transaction” means any transaction other than a transaction carried out in the course of an established Business Relationship made by a person acting in the course of financial or other business.

“Politically Exposed Persons (PEPs)” is an individual who holds or has ever held one of the following positions in or on behalf of a foreign country:

a head of state or government;
a member of the executive council of government or member of a legislature;
a deputy minister (or equivalent);
an ambassador or an ambassador's attaché or counselor;
a military general (or higher rank);
a president of a state owned company or bank;
a head of a government agency;
a judge;
a leader or president of a political party in a legislature.

A politically exposed foreign person also includes the following family members of the individual described above:

mother or father;
child;
spouse or common law-partner;
spouse's or common-law partner's mother or father;
brother, sister, half-brother or half-sister (that is, any other child of the individual's mother or father).

“Regulations” means the Money Laundering (Prevention) Regulations.

The Manual sets out the basis of internal Anti Money Laundering and Anti-Terrorist Financing measures and procedures while the Company provides services to its Clients in ordinary business course.

According to current legislation the Manual shall be from time to time updated by duly appointed Compliance Officer (CО) and approved by the Board of Directors.

It is responsibility of CO and Board of Directors to make aware of the Manual all employees of the company dealing with money processing and transmission transactions.

It is important to understand that the Manual endeavors to cover regular cases and predictable situations, the Money Laundering and Terrorist Financing activity develop at high speed, so it is crucial to understand the core concept in order to recognize well-structured illegal transaction, and use professional commons sense rather than limited regulations of this Manual, as it is impossible to foresee all the possible cases of the Money Laundering and Terrorist Financing in one document.

For transactions over 10,000 USD particular attention must be given and a Declaration of Source of Funds form should be filled out. See Appendix 2 for the relevant form.

The Manual applies to all payment processing and money transmission services offered by the Company.

1. BOARD OF DIRECTORS STATEMENT AND RESPONSIBILITIES

The Board of Directors of SUVYD B.V. strongly believes that corporate integrity, which is defined as a company's systematic obligation to follow strict standards of ethical behavior is a source of stability and a necessary condition for maintaining customer confidence and loyalty.
Therefore, policies that support strict compliance with the legal framework governing the prevention of money laundering and terrorism financing are particularly important.
Consequently, the procedure and methods for achieving this goal are set out in the Anti - Money Laundering & Terrorist Financing Manual, which provides policy guidelines for effective prevention and control, as well as procedures for detecting and reporting activities that may be related to money laundering or terrorist financing.
The proper application of this Manual requires that the staff and the Board of Directors must be familiar with its contents, relevant procedures and regulations regulating these activities. All employees of SUVYD B.V. are required to comply with the contents of this Manual. Failure to comply with the criteria and instructions contained in this Manual will result in penalties and sanctions.
The responsibilities of the Board of Directors to prevent money laundering and terrorist financing include the following:

1. to determine, fix and approve the general principles of the Company's policy in the field of prevention of Money Laundering and Terrorism;
2. to appoint a responsible CO and, if necessary, to assist CO and identify her/his responsibilities as set out in the Manual;
3. approve the Manual and all relevant policies, which must be disclosed to all employees of the Company;
4. ensure that all requirements of the Law and of the Regulation are applied, and assure that appropriate, effective and sufficient systems and controls are introduced for achieving the abovementioned requirements;
5. to ensure full and prompt access for CO and her/his assistants, if any, to all data and information relating to the Clients' identity, transactions and other relevant files and information maintained by the Company so as to be fully facilitated in the effective execution of the duties, as included herein;
6. ensure that all employees are aware of the person who has been assigned to the duties of the CO, as well as her/his assistants (if any), to whom they report any information regarding transactions and activities for which they that they know or suspect may be related to Money Laundering and Terrorist Financing;
7. establish a clear and prompt reporting system whereby information on suspicious transactions is promptly transmitted directly or through assistants (if any) to the CO, either directly or through her/his assistants, if any, and notifies accordingly the CO for its explicit prescription in the Manual;
8. to ensure that the CO has sufficient resources, including competent team and technological equipment, to perform its duties effectively;
9. to ensure that all employees know the person to whom they should report suspicious transactions related to Money Laundering or Terrorist Financing;
10. to ensure that there is a clear reporting chain from the employees to the CO for reporting about sufficient transactions;
11. to ensure that there is an independent audit function to review compliance measures;
12. evaluate and obligate the CO to submit the Suspect Report to the authorities.

2. ANTI- MONEY LAUNDERING COMPLIANCE OFFICER (“CO”)

2.1. In order to meet compliance requirements, set out in the AMLR, the Company has appointed an Anti- Money Laundering Compliance Officer (“CO”). Senior management is responsible for the Company’s global compliance program with all international and local legal and regulatory requirements applicable to the Company. Senior management is responsible for the oversight, selection and monitoring of the CO. The Company relies on the CO, under the supervision of senior management, for the following responsibilities:

to create and establish the Client Acceptance Policy and submit it to the Board of Directors for consideration and approval;
to revise the Manual as soon as the need arises, the Board of Directors must approve any changes after revising;
to inform the Board when an STR (Suspicious Transaction Report) has been issued. The Board must be formally acknowledged.
to obtain information from employees of a Company that may be associated with or related to Money Laundering or Terrorist financing activities. Information needs to be received in the form of a written report (hereinafter referred to as the "Internal Suspect Report"), a sample of which is attached in Annex 1 to the Guidelines;
if there are any assumptions about any suspicious transactions the CO must submit Internal Suspect Report to the Board of Directors at first and if assumptions are confirmed, the board of directors decides and obligate the CO to submit the report to the authorities.
to evaluate the information obtained in accordance with paragraph above, evaluation of such information should be made in the report (hereinafter referred to as the “Internal Evaluation Report”);
to act as the first contact person with any authority related to the fight against Money Laundering in the FIU / MOT;
to provide initial and updated training for all relevant staff, including all staff who handle any transactions, and customer payments;
to identify, register and evaluate, at least on an annual basis, all risks arising from existing and new Clients, new financial instruments and services, as well as update and modify the systems and procedures used by the Company to effectively manage the aforementioned risks;
to check the systems and procedures applied by a third person on whom the Company may rely for Client identification and due diligence purposes and approve the cooperation with it;
to keep informed and updated the Board of Directors about all legal matters and regulations that affect the Company in their management of the prevention against money laundering
to acquire the knowledge and skills necessary to improve the proper procedures for identifying and preventing any operations and actions that are presumably related to Money Laundering or Terrorist Financing;
to determine whether the Company's employees need further training for the purpose of preventing Money Laundering and Terrorist Financing and organize appropriate training sessions/seminars. In this respect, the CO prepares and applies an annual staff training program. Also, the CO assesses the adequacy of the education and training provided;
to prepare the Annual Report;
to respond to all requests and queries from the Curaçao authorities including FIU/MOT and Regulator, provide all requested information and fully cooperate with the Curaçao authorities including FIU/MOT and Regulator.
The CO is responsible, in consultation with the senior management of the Company and the employee / internal audit department, for the implementation of the various Directives and instructions / recommendations that may be required in accordance with law.
to implement the necessary remedial measures as a result of observations made by the Internal or External Audit or Regulatory Body.
The CO must act honestly and reasonably and to make his/her decision in legal way.

3. ANNUAL INDEPENDENT ASSESSMENT OF AML PROGRAM

The assessment must be conducted by a qualified independent third party. The independent third party must have an adequate working knowledge of the Curacao requirements under the FIU/MOT and its Regulations. Cost of the independent third party will be borne by the Company.
The Annual Report addresses issues related to Money Laundering and Terrorist Financing during the period under review and includes, but is not limited to:
1. information on the measures and / or procedures taken to comply with any changes and / or new provisions of the Law and the Regulations which took place;
2. the inspection information must be provided in the CO reports on significant deficiencies identified in the Company's policies, practices, measures, procedures and controls on Preventing Money Laundering and Terrorist Financing. In this regard, the Annual Report should outline the seriousness of the weaknesses, the impact of the risk and the corrective action taken;
3. adequacy of the Company AML policies and procedures in line with FIU/MOT requirement;
4. adequacy and appropriateness of the Player Risk Assessment completed by Company;
5. information, details or observations regarding communication with employees on Money Laundering and Prevention of Terrorist Financing;
6. information on the policies, measures, practices, procedures and controls applied by the Company with respect to high-risk clients, as well as the number and country of origin of the high-risk Сlients with whom the business relationship is;
7. information on the systems and procedures used by the Company to monitor the Client's accounts and operations on an ongoing basis;
8. information on training courses / seminars attended by CO and any other training material received;
9. information on trainings and any other educational materials provided to employees during the year, reporting about the number of courses / seminars organized, their duration, the number and position of staff attending, the names and qualifications of teachers, and specifying whether the courses / seminars were developed in-house or external organization or consultants;
10. the results of the assessment of the adequacy and effectiveness of staff training;
11. assess whether the Company AML policies and procedures provide enough guidance to employees to adequately verify the identity of the Players and perform risk assessments consistent with regulatory requirements.
12. ensure prescribed PEP due diligence measures are being performed in an adequate manner and reasonable measures are taken.
13. confirmation of appropriate levels of ongoing monitoring of transactions and business relationships is conducted for all Players in line with FIU/MOT regulations and regulatory expectations.
14. confirmation of appropriate records are maintained as per the record keeping requirements.

4. CLIENT ACCEPTANCE POLICY

The Client Acceptance Policy (hereinafter - “CAP”) defines the criteria for accepting new Clients and defines the criteria for classifying the Client that the Company should follow, and especially the employees who should participate in the process of opening of client accounts.
The CO is responsible for applying all of the provisions of the CAP.

4.1. General Principles of the client acceptance

The general principles of CAP are as follows:

(a) The Company shall classify Clients according to different risk categories and, based on risk perception, establish eligibility criteria for each Client category.

(b) If the Customer is a new Customer, the account can only be activated after appropriate due diligence and identification measures and procedures were carried out in accordance with established principles and procedures.

further in the Anti-Money Laundering Guidelines.

(d) Customers are not accepted under anonymous or fictitious names.

(e) No account may be opened unless the prospective Customer is approved by the General Manager and/or CO.

4.2. Criteria for Accepting New Clients

4.2.1. Below is a list of Criteria for accepting new clients based on their risk categories.

4.2.1.1. Low Risk Clients

The Company is classified as a low-risk Client, subject to compliance with the general principles of the Guide.
A simplified identification and due diligence procedure is provided for low-risk clients.

4.2.1.2. Normal Risk Clients

The Company shall accept Clients who are categorized as normal risk Clients as long as the general principles under the Manual are followed.

4.2.1.3. High Risk Clients

The Company shall accept Clients who are categorized as high risk Clients as long as the general principles under the Manual are followed.
For high-risk Customers, the Company applies enhanced customer identification measures and due diligence procedures.

4.2.1.4. Not Acceptable Clients

The Company recognizes the following categories of persons as Clients who are not acceptable for establishing business relations or performing irregular transactions with the Company:

- Netherland Antilles residents;
- Clients who fail or refuse to submit, the requisite data and information for the verification of his identity, residential address and the creation of his economic profile, without adequate justification (as stated at the Manual);
- Clients in the list issued by Anti-Money Laundering CO;
- The Company shall not conduct transactions in cases where the identity of the client matches with any person with known criminal background or with banned entities such as individual terrorists or terrorist organization’s etc. whose name appear in the lists/s published from time to time
- Clients who provide incorrect/incomplete information, who are involved in illegal activity, who are involved with terrorism;
- Underaged clients;
- Residents of countries where games of chance are illegal;
- PEPS.

4.2.2. Criteria for client classification

4.2.2.1. The Company classifies customers based on risk into the three categories listed below:

Low Risk Clients

The Company includes the following as low-risk clients:

credit or financial institution covered by the Regulations;
credit or financial institution carrying out one or more of the financial business activities as these are defined by the Law and which is situated in a country outside the EEA, which:

in accordance with a decision of the Regulator, imposes requirements equivalent to those laid down by the Regulations, and
it is under supervision for compliance with those requirements.

listed companies whose securities are admitted to trading on a Regulated Market in a country of the EEA or in a third country which is subject to disclosure requirements consistent with community legislation
domestic public authorities of countries of the EEA.

Normal Risk Clients

The Clients, who do not fall into the categories of "Low Risk Clients" or "High Risk Clients" are classified as Normal Risk Clients with respect to money laundering and terrorist financing risks.

High Risk Clients

Clients with a high level of money laundering and terrorist financing risk include:

(a) Clients who are not physically present for identification purposes.

(b) Clients whose own shares or shares of their parent companies (if any) were issued in bearer form.

(d) “Client Accounts” in the name of a third party.

(e) PEP accounts.

(f) Clients who participate in electronic gambling / internet games.

(g) Clients from countries that inappropriately apply the FATF recommendations.

(h) Cross-border correspondent banking relations with credit institutions-Clients from third countries.

(i) any other Customers that, by their nature, entail a higher risk of money laundering or terrorist financing.

(j) any other Client identified by the Company as being classified as such.

The Anti-Money Laundering CO is responsible for assigning Clients to one of three categories based on the criteria for each category above. In order to assign a client to a certain category, the Company must collect sufficient information. This information must be properly documented and stored. OG is responsible for the proper collection of the specified information.

5. CLIENT DUE DILIGENCE AND IDENTIFICATION PROCEDURES

The due diligence and identification procedures are used in relation to anti-money laundering, and both are used globally to describe client identification and verification procedures, which comprise the FIU/MOT obligations. Collectively and for the purposes described in this manual, both of these terms encompass the various elements and stages that are required for taking on new customers and reviewing existing customers.
The Company shall duly provide Client identification procedures and Client due diligence measures in any case of establishing a Business Relationship and when there is any assumption of Money Laundering or Terrorist Financing, regardless of the amount of the transaction.
The Company could additionally provide Client identification procedures and Client due diligence measures when there are doubts about the reliability or adequacy of previously Client identification data.
It is obligatory to conduct Client identification procedures and Client due diligence measures at the 2000 EUR threshold of the transaction.

5.5. Time of Application of the Client Identification and Due Diligence Procedures

The Client Identification and Due Diligence Procedures should be provided and controlled by the CO in the following cases:
1. The verification of the identity of the Client and the Beneficial Owner must be carried out before establishing a Business Relationship or conducting a transaction.
2. All prospective clients must be subjected to the process of identification upon registration, which involves the gathering of minimum necessary personal data of the Client. Clients shall be prohibited from opening anonymous accounts or accounts under fictitious names.
3. In cases where the Company is unable to comply with points 1 and 2 of Section 5.5. of the Manual, the Company shall not carry out any transaction or establish a Business Relationship or carry out an Occasional Transaction and consider making a report to the FIU/MOT.
4. Identification procedures and Client due diligence requirements shall be applied not only to all new Clients but also to existing Clients at appropriate times.

5.6. Construction of a Personal Profile and General Client Identification and Due Diligence Principles

The construction of the Client’s personal profile must include/follow the principles below:
1. an important transaction is occurring, which seems unusual and / or significant in comparison to the usual transaction pattern and economic profile of the Client.
2. For the purposes of the provisions relating to identification procedures and Client due diligence requirements, proof of identity shall be deemed to be satisfactory if:

The company must be sure that it is dealing with a real person and, for this reason, the Company will receive sufficient proof of identity. In addition, the Company must verify the identity of the Beneficial Owner (s) of the Client's accounts.
The verification of the Clients’ identification should be based on reliable data and information issued or obtained from independent and credible sources, that is, data and information that is most difficult to change or obtain illegally.
A person’s residential and business address will be an essential part of her/his identity.
The said data and information are recorded in a separate form designed for this purpose which is retained in the Client's file along with all other documents as well as all internal records of meetings with the respective Client. The said form is updated regularly or whenever new information emerges, that needs to be added to the economic profile of the Client or alters existing information that makes up the economic profile of the Client;
Ensure that the Client identification records remain completely updated with all relevant identification data and information about the Business Relationship.
The outcome of the said review shall be recorded in a separate note/form which shall be kept in the respective Client file.
Client and the data and information kept for the Client’s personal profile;
significant deviations shall be investigated and the findings shall be recorded in the respective Client’s file; transactions that are not justified by the available information on the Client, shall be thoroughly examined, so as to determine whether suspicions over money laundering or terrorist financing arise for the purposes of submitting an internal report..
In addition to the obligations set out in the two paragraphs above, the Company checks the adequacy of the Client's identity and personal profile when one of the following events or incidents occurs:

1. 1. 1. a. It is reasonable possible to establish that the Client is the person he claims to be; and,
    2. b. The person who examines the evidence is satisfied, in accordance with the appropriate procedures, that the Client is actually the person he claims to be.

5.7. Simplified Client Identification and Due Diligence Procedures

Simplified Due Diligence is the lower level of customer due diligence that is conducted on an individual that poses a low risk of money laundering or act of terrorist financing. In Simplified Due Diligence, the individual poses a lower risk than Standard Due Diligence and far lesser risk than customers in the Enhanced Due Diligence category.
With respect to the provisions of the Law and the Regulation for simplified Client Identification and Due Diligence Procedures, the following shall apply:
the Company will Identifying and verifying individual customer identity: confirming who a Client claims to be and establishing that they are who they claim to be
Identifying and verifying business Client Ultimate Beneficial Owners: determining who ultimately owns and controls a business entity or nonprofit
Evaluating customer risk by understanding the nature and purpose of customer relationships: given that the customer is who they claim to be, weighing how much risk of money laundering they pose
Monitoring transaction risk: tracking transactions, flagging suspicious activity, establishing reporting procedures, and keeping customer identifying data up-to-date (for example, confirming a business address hasn't changed since the customer opened the account)

5.8. Enhanced Client Identification and Due Diligence (High Risk Clients)

The Company follows a risk-based approach, the amount and type of information obtained, and the extent to which this information is verified, must be increased where the risk associated with the business relationship is higher.
As a general rule the CO shall apply enhanced due diligence measures with respect to the Clients categorized as high risk Clients according to the criteria set in the Manual.
These measures include the following:
Obtaining additional identifying information from a wider variety or more robust sources and using the information to inform the individual client risk assessment;
Carrying out additional searches (verifiable adverse media searches) to inform the individual client risk assessment;
Commissioning an intelligence report on the client or beneficial owner to understand better the risk that the client or beneficial owner may be involved in criminal activity;
Verifying the source of funds or wealth involved in the business relationship to be satisfied that they do not constitute the proceeds from crime;
Seeking additional information from the Client about the purpose and intended nature of the business relationship;
With respect to transactions or Business Relationships with PEPs, the Company shall:

i. have necessary risk-based procedures to establish whether the Client (or the Beneficial Owner) is a PEP.

ii. have senior management permission to establish business relationships with such Clients or to continue business relationships with existing Clients who have become PEP.

iii. take adequate measures to establish the source of funds.

iv. conduct enhanced on-going monitoring of the Business Relationship.

Below are described due diligence and identification procedures with respect to high risk Clients:

5.9 “Politically Exposed Persons” accounts

The Company shall apply the following with respect to the accounts of “Politically Exposed Persons”:

The Company shall pay more attention when the said persons originate from a country which is widely known to face bribery, corruption and financial irregularities and whose laws and regulations against Money Laundering are not equivalent to international standards.
In order to effectively manage such risks, the Company must evaluate the countries of origin of its Clients, to identify countries that are more vulnerable to corruption, or to support laws and regulations that do not comply with the FATF requirements.
With regard to the issue of corruption, one useful source of information is the Transparency International Corruption Perceptions Index which can be found on the website of Transparency International at www.transparency.org.
With regard to the issue of adequacy of application of the 40+9 recommendations of the FATF, the Company shall retrieve information from the country assessment reports prepared by the FATF or other regional bodies operating in accordance with FATF’s principles (e.g. Moneyval Committee of the Council of Europe) or the International Monetary Fund.
According to the meaning of the Manual, PEPs are the natural persons who are residing in any country and who are or have been entrusted with prominent public functions and immediate family members, or persons known to be close members of such persons.
The meaning ‘Politically Exposed Persons’ includes the following natural persons who are or have been entrusted with prominent public functions’ in any country:

1. 1. heads of State, heads of government, ministers and deputy or assistant ministers
  2. members of parliaments
  3. members of supreme courts, of constitutional courts or of other high-level judicial bodies whose decisions are not subject to further appeal, except in exceptional circumstances
  4. members of courts of auditors or of the boards of central banks
  5. ambassadors and high-ranking officers in the armed forces
  6. members of the administrative, management or supervisory bodies of State-owned enterprises.

Without prejudice to the application where a person has ceased to be entrusted with a prominent public function within the meaning of point above for a period of at least one year, the Company shall not be obliged to consider such a person as politically exposed.

7. None of the categories set out in point above shall be understood as covering middle ranking or more junior officials. ‘Immediate family members’ includes the following:

1. the spouse or the person with which cohabit for at least one year
2. the children and their spouses or the persons with which cohabit for at least one year
3. the parents.
‘Persons known to be close associates’ includes any natural person who is known to have joint Beneficial Ownership of legal entities or legal arrangements, or any other close business relations, with a person referred to in point above as “members of parliaments” any natural person who has sole Beneficial Ownership of a legal entity or legal arrangement which is known to have been set up for the benefit de facto of the person referred to in point above as “members of parliaments”.
Once the PEP has been subject to establishing business activity, Company should apply risk based due diligence procedures, which may include:
1. Understanding and documenting the length of time, the title or position and country in which the PEP holds, or held, political exposure. If the individual customer is a close family member or close associate, the relationship of the person to the PEP must be documented
2. Understanding and documenting the nature and intended purpose of the relationship/account, the source of the initial funds (where appropriate) and the anticipated levels of account activity
3. Understanding and documenting the customer’s source of funds and source of wealth (e.g. salary and compensation from official duties and wealth derived from other sources). Where the financial crime risks are high or there are doubts as to the veracity of the information provided by the customer, FIs should validate this information using independent and reliable sources. FIs may use internet and media searches to determine and/or validate this information, having considered the potential limitations of such sources
4. When the due diligence on an immediate family member or close associate of a PEP indicates that the source of funds originates from the PEP, then the FI should determine and document the PEP’s sources of funds and wealth. Negative News/Adverse Media Screening on the PEP who funds the account may assist in establishing whether the PEP has deliberately attempted to disguise their involvement in funding the account
5. the decision for establishing a Business Relationship or the execution of an Occasional Transaction with a PEP is taken by an Executive Director of the Company and the decision is then forwarded to the CO
6. before establishing a Business Relationship or executing an Occasional Transaction with a PEP, the Company shall obtain adequate documentation to ascertain not only the identity of the said person but also to assess the business reputation (e.g. reference letters from third parties)
7. the Company creates an economic profile of the Client by obtaining information. Detailed information about the expected business and the nature of the Client’s activities forms the basis for future account monitoring. The profile should be regularly reviewed and updated with new data and information. A company should be especially cautious and vigilant when its Clients are involved in a business that appears to be most vulnerable to corruption, such as the sale of oil, weapons, cigarettes, and alcohol.
8. the account is subject to annual review to determine whether to permit its continuation. A short report should be prepared with a summary of the results of the verification by the person responsible for monitoring the accounts. The report is sent for consideration and approval to the Board of Directors and is stored in the personal file of the Client.

5.10. High-risk and non-compliant countries

There are certain geographic locations considered as higher risk for money laundering and terrorist financing.

Those that are not members of the Financial Action Task Force (FATF), or regional FATF‐like bodies groups of similar nature such as the Financial Actions Task Force of South America (GAFISUD), Caribbean Financial Action Task Force (CFATF), Middle East/North Africa Financial Action Task Force (MENAFATF), Asia/Pacific Group on Money Laundering (APG), and so on
The Company shall apply the following with respect to Clients from countries which inadequately apply FATF’s recommendations:
1. verifying the legitimacy of the source of funds and the source of wealth of the Client.
2. If there are any inconsistencies found in the earnings, source of wealth, source of funds, and net worth of the customer, additional documents may be required to confirm the origin of funds to fully justify the above-mentioned inconsistencies.
3. It is necessary to assess all available customer transaction history and access transaction details such as the:

- - Background of the transaction;
  - Purpose of the transaction;
  - Nature of the transaction;
  - Duration of the transaction;
  - Parties involved.

4. According to the СO decision, the Company applies, when necessary, enhanced due diligence measures to identify and monitor the operations of persons originating from countries with significant weaknesses and strategic weaknesses in their legal and administrative systems, to prevent Money Laundering and the Financing of Terrorism.

5.11. Client Identification and Due Diligence Procedures (Specific Cases)

The company is not entitled to take on board resident customers of the Netherlands Antilles.
The CO must ensure that the relevant documents and information regarding the following cases are duly received, as the case may be:
1. true name and/or names used as these are stated on the official identity card or passport
2. full permanent address, including postal code
3. telephone (home and mobile) and fax numbers
4. e-mail address, if any
5. date and place of birth
6. nationality

To verify the identity / name of the Client, the Company must request from the Client the original document issued by an independent and reliable source with a photograph of the Client (for example, passport, identity cards, driver’s license, etc.). After the Company has verified the identity of the Client from the original document submitted, it will keep copies.

Provided that the Company can prove that the specified document was issued from an independent and reliable source. In this regard, the CO is responsible for assessing the independence and reliability of the source and should properly document and submit the relevant data and information used for the assessment, as appropriate.

The Client’s permanent address shall be verified using one of the following ways:

(b) presenting of a recent (up to 6 months) utility bill, local authority tax bill or a bank statement or any other document same with the aforesaid

In addition to the foregoing, the Company should request and receive information on public positions that a potential Client has held during the past twelve (12) months, as well as whether she/he is a close relative or partner of such a person, to check if the client is PEP.

In addition to the above, the procedure for the verification of a Client’s identity is reinforced if the said Client is introduced by a reliable staff member of the Company, or by another existing reliable Client who is personally known to a member of the Board of Directors. Details of such introductions are kept in the Client’s file.

6. ON-GOING MONITORING PROCESS

Once identification procedures are complete and the Company has established a relationship with the Client, the Company must continue to monitor Client structure and any activity, if apparent, to ensure that it is consistent with expectations and to ensure that due diligence documentation remains up to date and in keeping with current requirements. The frequency and nature of the monitoring processes will depend upon the type of client, the business undertaken, and the risk rating assigned to the client.
Continuous monitoring of Clients' accounts and transactions is a mandatory element of effective control over the risk of Money Laundering and Terrorist Financing.
In this regard, the CO is responsible for maintaining and developing the current monitoring process of the Company. The external auditor should review the Company's procedures with respect to the ongoing monitoring process at least annually.
On-going monitoring procedure applies to clients suspected of committing illegal transactions as well. In order to remove any suspicions in regard to such clients we may request the following documents:

- Personal identification documents of the Client:
- Passport (first page);
- National identity card (front and back);
- Driving License;
- Proof of permanent address (a utility bill such as for gas, electricity not older than 3 months or bank statement);
- Your selfie with a passport or ID.
- Other KYC documents.
  Documents should be provided in the format of high-resolution color photo. Scanned versions are not allowed. Document pages should be fully visible

The Company shall periodically conduct a review of CDD information, activity and transactions, and internet searches for all clients. The frequency of the review will be based on the Risk Assessment: High Risk Clients will be reviewed annually; Medium Risk Clients every 2 years and Low Risk Clients will be reviewed every three years.
The procedures and the intensity of monitoring Clients’ accounts and examining transactions on the Client’s level of risk shall include the following:

1. ensure that client activity conforms with the stated information at the time the relationship was established. (i.e. license status, volume of activity, etc.)
2. CO receives an analysis once a week from the Back Office Department/officer as regards any unusual or suspicious transactions.
3. ensure that due diligence documentation remains appropriate
4. the results of the investigations are recorded in a separate memo and stored in the files of the respective clients, CO receives daily entries about incoming and outgoing money transfers; and ascertains the source and origin of funds credited to accounts capable of timely submission to the Board of Directors and CO;

1. the use of appropriate and proportionate IT systems.

7. RECOGNITION AND REPORTING OF SUSPICIOUS TRANSACTIONS / ACTIVITIES TO THE FIU/MOT

Reporting of Suspicious Transactions to the FIU/MOT (See Appendix 3)
The Company, in cases where there is an attempt to carry out transactions known or suspected to be related to money laundering or terrorist financing, reports, through the CO its suspicion to the FIU/MOT. In cases where there is an attempt to carry out transactions known or suspected to be related to money laundering or terrorist financing, the Company shall immediately inform through the CO its suspicion of the FIU / MOT.
Suspicious Transactions

The definition of a suspicious transaction, as well as the types of suspicious transactions that can be used for Money Laundering and Terrorist Financing, are practically unlimited. A suspicious transaction is often understood as a transaction that is incompatible with the normal business of a particular account. The Company must ensure that it contains adequate information and knows enough about the activities of its Clients in order to recognize in a timely manner that the transaction or series of transactions is unusual or suspicious.
Unusual activity is that which is not consistent with customer's known or expected activity or is abnormal for the type of customer or structure. The key to identifying unusual activity is to know enough about a particular customer and its normal activity to be in a position to recognize anything unusual. There is an important distinction between activity that is considered to be unusual and activity that is believed to be, or known to be, connected with criminal conduct, money laundering or terrorist financing. The Inter
American Drug Abuse Control Commission (CICAD) of the Organization of American States (OAS), defines Suspicious Transaction as those transactions, completed or not, complex, unusual, significant, any kind of non-habitual transaction and all transactions that although are not significant are recurrent in time, that appear to serve no evident financial, business or legal purpose.
In order to identify suspicious transactions, the CO shall perform the following activities:

1. 1. to track on a regular basis any changes in the Client's financial activities on the Company's website.
  2. receive and investigate information from heads of departments / supervisors of the Company and relevant employees about suspicious transactions, which creates the belief or suspicion of money laundering. This information is reported on the Internal Suspicion Report, the said reports are archived by the CO.
  3. evaluate and verify the information received from the Heads of Departments/Supervisors and the relevant employees of the Company.
  4. if, as a result of the evaluation described above, the CO decides to disclose this information to the FIU/MOT, then she/he prepares a written report, which she/he submits to the FIU/MOT.
  5. If, as a result of the evaluation described above, the CO decides not to disclose the relevant information to the FIU/MOT, then he fully explains the reasons for her/his decision on the Internal Evaluation Report.

Submission of Information to the FIU/MOT

Employees are required to report any suspected criminal behavior directly to the CO as soon as possible. The report must be written. After it is determined that the activity is suspicious, no further inquiries should be made of the client and the client should never be informed that someone considers his or her activity to be suspicious or that a Suspicious Activity Report (SAR) has been or will be filed.

The company must ensure that in the event of an investigation of a suspicious transaction, CO will be able to immediately provide the following information to FIU/MOT:

the identity of the Beneficial Owners of the account
the identity of the persons authorized to manage the account
the identity of the account holders
data of the volume of funds or level of transactions flowing through the account
in relation to specific transactions:
- the origin of the funds.
- the type and amount of the currency involved in the transaction.
- the form in which the funds were placed or withdrawn, for example cash, cheques, wire transfers.
- the identity of the person that gave the order for the transaction e.g., the destination of the funds.
- the form of instructions and authorization that have been given.
- the type and identifying number of any account involved in the transaction.
Submission of Information to the FIU/MOT
The company must ensure that in the event of an investigation of a suspicious transaction, CO will be able to immediately provide the following information to FIU/MOT:
the identity of the account holders
the identity of the Beneficial Owners of the account
the identity of the persons authorized to manage the account
data of the volume of funds or level of transactions flowing through the account
in relation to specific transactions:

the origin of the funds.
the type and amount of the currency involved in the transaction.
the form in which the funds were placed or withdrawn, for example cash, cheques, wire transfers.
the identity of the person that gave the order for the transaction e.g. the destination of the funds.
the form of instructions and authorization that have been given.
the type and identifying number of any account involved in the transaction.

8. RECORD-KEEPING

The Company shall maintain records of:
Records of customer screening (PEPs & Sanctions);
Copies of, or references to, the evidence obtained of a customer’s identity for five years after the end of the customer relationship;
Details of customer transactions for five years from the date of the relevant transaction;
Records of all AML/CTF training delivered;
Details of actions taken in respect of internal and external suspicion reports;
Details of information considered by the MLRO or his nominee in respect of an internal report where no external report is made.
Documents/data are stored for at least five years, which is calculated after the transaction or termination of the Business relationship.
If the documents/data specified in points (a-f) above may be relevant to ongoing investigations, they are retained by the Company until the FIU/MT confirms that the investigation is complete, and the case is closed.
The Administration/service department/employee may store documents/data in forms other than printed ones, in electronic form, provided that the free access of the Administration/service department/employee to the receipt of relevant documents/data is guaranteed without undue delay and the possibility is ensured at any time to send them to the regulatory body or FIU / ILO upon request. This provision does not apply to original documents or their certified copies, which must be kept in printed form.
All personal information about which is received based on this Policy is processed according to our Privacy & Management of Personal Data Policy.

Appendix 1

INTERNAL SUSPICION REPORT FOR MONEY LAUNDERING AND

TERRORIST FINANCING

INFORMER’S DETAILS

Name: ............................................................... Tel: ............................................. Department: ...................................................... Fax: ............................................ Position: .................................................................................................................

CLIENT’S DETAILS

Name: ................................................................ ..................................................

Address: ............................................................ ..................................................

Date of Birth: ............................

Tel: ...................................................................

Occupation:............................... Fax: ...................................................................

Details of Employer: ................

..................................................Passport No.: .....................................................

Nationality: .............................. ID Card No.: ..................................................... Other ID Details: .....................

INFORMATION/SUSPICION

Brief description of activities/transaction: ..... ..................................................

.......................................................................... ..................................................

Reason(s) for suspicion:.................................... ..................................................

........................................................................... ..................................................

Informer’s Signature Date

............................................ ……………………………....

FOR CO USE

Date Received: ........................... Time Received: ..................... Ref. ................ Reported to the FIU/MOT: Yes/No .... Date Reported: ...................... Ref .................

Appendix 2

Declaration of Source of Funds

(Company Logo) SUVYD B.V.

(Address)

(Telephone No./Fax No)

(Email Address)

DECLARATION OF SOURCE OF FUNDS

Client Name: ____________________________ Account Number:______________________

Address: ______________________________________________________________________________

Amount of Transaction and Currency: ___________________________________________________________

Purpose of Transaction:____________________________________________________________________

______________________________________________________________________________

Cheques Payment: ________________________ Other: __________________________

Wire Transfer Payment: _____________________________

Source of Funds:

___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Enclosed Supporting Evidence:

___________________________ _________________________

Customers Signature Date

Official Use Only

Transaction Approved: Yes No

If no, state Reason: ____________________________________________________________________________________________________________________________________________________________

_________________________________ ________________________________

Officer Completing Transaction Authorizing Officer

Operations Department AML Compliance Department

(Signature and Date) (Signature and Date)

Appendix 3

FINANCIAL INTELLIGENCE UNIT

Suspicious Transaction Report

SECTION 17(4)(b) OF THE MONEY LAUNDERING & TERRORISM (PREVENTION) ACT, 2008

SECTION 7(3) OF THE FINANCIAL INTELLIGENCE UNIT ACT, 2002

(Complete all applicable parts - See Instructions)

Part I	Reporting Entity/Financial Institution Information							1
Name of Reporting Entity/Financial Institution
Address of Reporting Entity/Financial Institution
3. Address of Branch Office(s) where activity occurred
4. Account number(s) affected, if any Closed Closed a _ ⬜ Yes ⬜ No c _ _ ⬜ Yes ⬜ No b _ ⬜ Yes ⬜ No d _ _ ⬜ Yes ⬜ No
Part II	Suspect Information ⬜ Suspect Information Unavailable
5. Last Name or Name of Entity			6. First Name				7. Middle Name
8. Address
9. Phone Number – Residence				10. Phone Number – Work
11. Occupation/Type of Business		12. Date of Birth _ _/ _ / _ MM DD YYYY				13. Admission/Confession? a ⬜ Yes b ⬜ No
14. Forms of Identification for Suspect: a ⬜ Driver’s License b ⬜ Passport c ⬜ Social Security Card d ⬜ Other Certificate of Incorporation Number _ Issuing Authority _
15. Relationship to Reporting Entity/Financial Institution: a ⬜ Accountant c ⬜ Attorney e ⬜ Customer h ⬜ Officer b ⬜ Agent d ⬜ Borrower f ⬜ Director i ⬜ Shareholder g ⬜ Employee j ⬜ Other _
16. Is the relationship an insider relationship? a ⬜ Yes b ⬜ No If Yes specify: c ⬜ Still employed at reporting entity/financial institution d ⬜ Suspended e ⬜ Terminated f ⬜ Resigned					17. Date of Suspension, Termination, Resignation _ / _ / _ MM DD YYYY
Part III	Suspicious Activity Information							2
18. Date or date range of suspicious activity From _ / _ / _ To _ / _ / _ MM DD YYYY MM DD YYYY				19. Total dollar amount involved in known or suspicious activity
20. Summary characterization of suspicious activity: a ⬜ Money Laundering f ⬜ Computer Intrusion l ⬜ Debit Card Fraud b ⬜ Bribery g ⬜ Consumer Loan Fraud m ⬜ Defalcation/Embezzlement c ⬜ Check Fraud h ⬜ Counterfeit Check n ⬜ False Statement d ⬜ Check Kiting i ⬜ Counterfeit Credit/Debit Card o ⬜ Misuse of Position e ⬜ Commercial Loan Fraud j ⬜ Counterfeit Instrument (other) p ⬜ Mortgage Loan Fraud q ⬜ Mysterious Disappearance r ⬜ Wire Transfer Fraud s ⬜ Other _ (Type of Activity)
21. Amount of loss prior to recovery (if applicable)		22. Dollar amount of recovery (if applicable)					23. Has the suspicious activity had a material impact on, or otherwise affected, the financial soundness of the reporting entity/institution? a ⬜ Yes b ⬜ No
24. Has any law enforcement agency already been advised by telephone, written communication, or otherwise? a ⬜ Yes b ⬜ No Agency Name _
25. Name of person(s) contacted at Law Enforcement Agency					26. Phone Number
Part IV	Contact for Additional Information
27. Last Name			28. First Name				29. Middle Initials
30. Title/Occupation		31. Phone Number				32. Date Prepared _ / _ / _ MM DD YYYY

Part V

Suspicious Activity Information Explanation/Description

Explanation/description of known or suspected violation of law or suspicious activity.

This section of the report is critical. The care with which it is written may make the difference in whether or not the described conduct and its possible criminal nature are clearly understood. Provide below a chronological and complete account of the possible violation of law, including what is unusual, irregular or suspicious about the transaction, using the following checklist as you prepare your account. If necessary, continue the narrative on a duplicate of this page.

a Describe supporting documentation and retain for

5 years.

b Explain who benefited, financially or otherwise, from the transaction, how much, and how.

c Retain any confession, admission, or explanation of the transaction provided by the suspect and indicate to whom and when it was given.

d Retain any confession, admission, or explanation of the transaction provided by any other person and indicate to

whom and when it was given.

e Retain any evidence of cover-up or evidence of an attempt to deceive federal or state examiners or others.

f Indicate where the possible violation took place (e.g., main office, branch, other).

g Indicate whether the possible violation is an isolated incident or relates to other transactions.

h Indicate whether there is any related litigation; if so, specify.

i Recommend any further investigation that might assist law enforcement authorities.

j Indicate whether any information has been excluded from this report; if so, why?

k If you are correcting a previously filed report, describe the changes that are being made.

For Money Laundering reports, include the following additional information:

l Indicate whether currency and/or monetary instruments were involved. If so, provide the amount and/or description of the instrument (for example, bank draft, letter of credit, money order, traveler’s checks, wire transfers sent or received, cash, etc.).

m Indicate any account number that may be involved or affected.

EXAMPLES OF SUSPICIOUS TRANSACTIONS/ACTIVITIES RELATED TO MONEY LAUNDERING AND TERRORIST FINANCING

Α. MONEY LAUNDERING

Large volume of transactions and/or money deposited or credited into, an account when the nature of the Client’s business activities would not appear to justify such activity.
The transfers of funds to the personal accounts are wired from or to an account of source of which the Client is not a Holder, e.g. from third party accounts.
All attempts of withdraws of fund that has been deposited but not waged.
The settlement of any transaction but mainly large transactions, in cash.

Settlement of the transaction by a third person which is different than the Client which gave the order.

Instructions of payment to a third person that does not seem to be related with the instructor.

Transfer of funds to and from countries or geographical areas which do not apply or they apply inadequately FATF’s recommendations on Money Laundering and Terrorist Financing.

A Client is reluctant to provide complete information when establishes a Business Relationship about the nature and purpose of its business activities, anticipated account activity, prior relationships with financial organizations, names of its officers and directors, or information on its business location. The Client usually provides minimum or misleading information that is difficult or expensive for the financial organization to verify.

A Client provides unusual or suspicious identification documents that cannot be readily verified.

A Client’s home/business telephone is disconnected.

A Client that makes frequent or large transactions and has no record of past or present employment experience.

Difficulties or delays on the submission of the financial statements or other identification documents, of a Client/legal person.

A Client who has been introduced by a foreign financial organization, or by a third person whose countries or geographical areas of origin do not apply or they apply inadequately FATF’s recommendations on Money Laundering and Terrorist Financing.

Shared address for individuals involved in cash transactions, particularly when the address is also a business location and/or does not seem to correspond to the stated occupation (e.g. student, unemployed, self-employed, etc.).

The stated occupation of the Client is not commensurate with the level or size of the executed transactions.

Financial transactions from non-profit or charitable organizations for which there appears to be no logical economic purpose or in which there appears to be no link between the stated activity of the organization and the other parties in the transaction.

Unexplained inconsistencies arising during the process of identifying and verifying the Client (e.g. previous or current country of residence, country of issue of the passport, countries visited according to the passport, documents furnished to confirm name, address and date of birth etc).

B. TERRORIST FINANCING

Sources and methods
The funding of terrorist organizations is made from both legal and illegal revenue generating activities. Criminal activities generating such proceeds include kidnappings (requiring ransom), extortion (demanding “protection” money), smuggling, thefts, robbery and narcotics trafficking. Legal fund raising methods used by terrorist groups include:

collection of membership dues and/or subscriptions;
sale of books and other publications;
cultural and social events;
donation;
Community solicitations and fund raising appeals.

Funds obtained from illegal sources are laundered by terrorist groups by the same methods used by criminal groups. These include cash smuggling by couriers or bulk cash shipments, structured deposits to or withdrawals from bank accounts, purchases of financial instruments, wire transfers by using “straw men”, false identities, front and shell companies as well as nominees from among their close family members, friends and associates

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