Anti-Money Laundering & Counter-Terrorism Financing Policy

1. Introduction and Legal Framework

This Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Policy establishes the principles and minimum standards that must be adhered to across all operations of CONVEXO FINANCE LIMITED.

We are committed to complying with all applicable AML/CFT laws, regulations, and industry standards in the jurisdictions where we operate, including but not limited to:

• Financial Action Task Force (FATF) Recommendations
• Local AML/CFT legislation
• Regulatory requirements specific to digital asset service providers

2. Know Your Customer (KYC) Procedures

CONVEXO FINANCE LIMITED implements robust KYC procedures to verify the identity of all clients:

For Individuals:

• Government-issued photo identification verification
• Proof of address verification (utility bills, bank statements)
• Source of funds declaration
• Politically Exposed Person (PEP) screening

For Businesses:

• Business registration and incorporation documents
• Corporate structure and Ultimate Beneficial Owner (UBO) identification
• Verification of authorized representatives
• Business activity assessment

3. Risk Assessment and Management

We employ a risk-based approach to AML/CFT compliance, assessing and categorizing clients and transactions based on various risk factors:

Client Risk Factors:

• Geographic location and jurisdiction
• Business activities and industry
• Political exposure
• Transaction patterns and volumes

Transaction Risk Factors:

• Source and destination of funds
• Transaction size and frequency
• Transaction patterns inconsistent with client profile
• Involvement of high-risk jurisdictions

Based on these assessments, we apply enhanced due diligence measures for higher-risk clients and transactions.

4. Transaction Monitoring

CONVEXO FINANCE LIMITED conducts ongoing monitoring of client transactions to detect and report suspicious activities:

• Automated systems to identify unusual transaction patterns
• Regular review of high-value and high-risk transactions
• Screening against sanctions lists and adverse media
• Periodic review of client profiles and risk assessments

5. Suspicious Activity Reporting

We maintain procedures for internal reporting of suspicious activities and external reporting to relevant authorities:

• Clear internal escalation protocols
• Prompt investigation of potential suspicious activities
• Timely filing of Suspicious Activity Reports (SARs) with appropriate authorities
• Confidentiality measures to protect the reporting process

6. Sanctions Compliance

CONVEXO FINANCE LIMITED ensures compliance with international and local sanctions regimes:

• Regular screening of clients and transactions against sanctions lists
• Blocking of transactions involving sanctioned individuals or entities
• Ongoing monitoring of changes to sanctions regimes
• Implementation of controls to prevent sanctions evasion

7. Record Keeping

We maintain comprehensive records of client identification, transactions, and compliance activities:

• Retention of all KYC documentation for at least 5 years
• Secure storage of transaction records
• Documentation of compliance decisions and actions
• Audit trail of all AML/CFT activities

8. Staff Training and Awareness

CONVEXO FINANCE LIMITED ensures that all employees receive appropriate AML/CFT training:

• Comprehensive onboarding training for new employees
• Regular refresher training for all staff
• Specialized training for compliance personnel
• Updates on emerging risks and regulatory changes

9. Independent Audit and Review

Our AML/CFT program is subject to regular independent review and testing:

• Periodic internal compliance reviews
• Regular independent third-party audits
• Timely remediation of identified deficiencies
• Reporting of audit results to senior management and board

10. Contact Information

For questions or concerns regarding our AML/CFT policies and procedures, please contact:

Compliance Officer
CONVEXO FINANCE LIMITED
contact@convexo.finance