ANTI-MONEY LAUNDERING (AML) POLICY

The purpose of the KNOW YOUR CUSTOMER (KYC) guidelines is to prevent financial institutions, whether intentionally or unintentionally, from being used by individuals or entities involved in criminal activities such as money laundering. Additionally, KYC procedures enable financial institutions to better understand their clients and their financial activities, which helps them manage risks effectively.

Financial institutions must implement effective ‘Know Your Customer’ (KYC) standards as an essential component of their risk management practices.

A key challenge in implementing sound KYC policies and procedures is establishing an effective approach. Legal and reputational risks are global in nature, so it is essential that each financial institution develop a global risk management program supported by policies incorporating KYC standards.

It is crucial that the adoption and implementation of customer acceptance policies do not become overly restrictive and do not result in denying services to individuals or communities that are financially or socially disadvantaged.

The term 'money laundering activities' refers not only to criminals attempting to launder illicitly gained funds, but also to bank or financial institution employees who knowingly participate in such transactions. "Knowledge" also includes the conscious avoidance of knowledge.

Definition of a Customer

For the purpose of the KYC policy, a customer may be defined as:

• A person or entity that holds an account and/or maintains a business relationship with Veeta Fx Global LTD.
• The ultimate beneficiary on whose behalf the account is maintained.
• Beneficiaries of transactions conducted by professional intermediaries, such as brokers, accountants, or lawyers, as permitted by law.
• Any individual or entity involved in a financial transaction that poses significant reputational or other risks to Veeta Fx Global LTD, such as a wire transfer or the issuance of a high-value check in a single transaction.

The KYC policy includes the following key elements:

1. Customer Identification Procedures
2. Transaction Monitoring
3. Risk Management
4. Training Program
5. Internal Control Systems
6. Record Keeping
7. Evaluation of KYC policies by internal audit
8. Responsibilities and Accountability

General Guidelines

Accounts of companies and firms

The Compliance Department of Veeta Fx Global LTD must remain vigilant to prevent individuals from using business entities as fronts to maintain accounts with the institution.

Veeta Fx Global LTD may analyze the control structure of the entity, determine the source of the funds, and identify the natural persons who hold controlling interest and are part of the management team. These requirements may be adjusted according to the level of risk perceived. For example, in the case of a publicly traded company, it may not be necessary to identify all shareholders.

Customer Identification Procedures (CIP)

The customer identification process may be carried out at the following stages, among others:

• When establishing the business relationship.
• When conducting a financial transaction.
• When Veeta Fx Global LTD has doubts about the authenticity or adequacy of previously obtained customer identification data.

Customer identification involves verifying the customer’s identity using reliable, independent documentation or information sources.

Veeta Fx Global LTD must gather enough information to satisfactorily establish the identity of every new customer, whether regular or occasional, and understand the purpose of the business relationship.

Satisfaction means that Veeta Fx Global LTD can demonstrate to the relevant authorities that due diligence has been exercised based on the customer’s risk profile, in compliance with the current guidelines.

Risk Assessment

An effective KYC program must be established through the creation of appropriate procedures and ensuring their proper implementation. This includes proper management oversight, control systems, segregation of duties, training, and other related matters. The responsibility must be clearly allocated within the company to ensure that policies and procedures are effectively implemented.

The level of due diligence will depend on the perceived risk by Veeta Fx Global LTD.

The customer profile will remain confidential, and the information contained within it will not be disclosed for cross-selling or other purposes.

Veeta Fx Global LTD's internal audit and compliance departments play a crucial role in evaluating and ensuring adherence to the KYC policies. The compliance function must provide an independent assessment of Veeta Fx Global LTD's policies and procedures, including legal and regulatory compliance.

Internal Inspection

Internal inspectors must specifically verify the application of KYC procedures at branches/offices and report any observed deficiencies in this regard.

Screening of Specially Designated Nationals and Sanctioned Parties

All customers must be screened through various independent risk intelligence databases.

Customer Identification

Natural Persons

For customers who are natural persons, Veeta Fx Global LTD must collect sufficient identification data (such as a passport, government-issued ID, etc.) to verify the customer’s identity, address/location (e.g., utility bill, bank statement), and, if possible, a recent photograph.

Legal Entities

For customers who are legal entities, Veeta Fx Global LTD must verify the legal status of the entity through proper and relevant documents, verify that any individual acting on behalf of the entity is authorized to do so, and identify and verify the identity of that individual. Veeta Fx Global LTD must also understand the ownership and control structure of the entity and determine the natural persons who ultimately control the entity.

Record Keeping

All identification documents and service records must be maintained for a minimum period of seven years.

Training

All new employees will receive anti-money laundering training as part of their mandatory onboarding process. Relevant employees must also complete annual AML training.

Administration

To implement this AML Policy, Veeta Fx Global LTD will appoint an AML Compliance Officer. This officer will be responsible for administering, reviewing, interpreting, and applying this policy. The AML Policy will be reviewed annually and updated as necessary.

The duties of the AML Compliance Officer will include, but are not limited to, the design and implementation of the policy, employee training, monitoring affiliates' compliance, maintaining necessary records, and conducting independent testing of the policy's effectiveness.