Anti-Money Laundering Policy

1. Introduction

AuroraEx Limited ("AuroraEx," "we," "our," or "us") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This AML Policy outlines our approach to preventing money laundering, terrorist financing, and other financial crimes through our platform.

Money laundering is the process of disguising the proceeds of criminal activity to make them appear legitimate. Terrorist financing involves the solicitation, collection, or provision of funds for terrorist activities. Both activities pose serious threats to the integrity of the global financial system and society as a whole.

As a responsible financial services provider, we have implemented a comprehensive AML/CTF program designed to detect, prevent, and report suspicious activities in accordance with applicable laws and regulations. This policy applies to all employees, officers, directors, and agents of AuroraEx, as well as our clients and business partners.

2. Regulatory Framework

AuroraEx is committed to complying with all applicable AML/CTF laws and regulations in the jurisdictions where we operate, including but not limited to:

• The Financial Action Task Force (FATF) Recommendations
• The Bank Secrecy Act (BSA) and its implementing regulations
• The USA PATRIOT Act
• The European Union Anti-Money Laundering Directives
• Local AML/CTF laws and regulations in the jurisdictions where we operate

We regularly monitor changes in the regulatory landscape and update our AML/CTF program accordingly to ensure ongoing compliance with evolving requirements.

3. AML/CTF Program

Our AML/CTF program consists of the following key components:

3.1 Risk-Based Approach

We apply a risk-based approach to AML/CTF compliance, allocating resources based on the level of risk associated with different clients, products, services, and jurisdictions. This approach allows us to focus our efforts on areas of higher risk while maintaining appropriate controls across all aspects of our business.

Our risk assessment methodology considers various factors, including:

• Client risk (e.g., occupation, source of wealth, PEP status)
• Product and service risk (e.g., complexity, liquidity, anonymity)
• Geographic risk (e.g., high-risk jurisdictions, sanctions)
• Channel risk (e.g., non-face-to-face relationships, third-party involvement)

Based on this assessment, we apply appropriate risk mitigation measures, including enhanced due diligence, transaction monitoring, and other controls as needed.

3.2 AML Compliance Officer

We have appointed a dedicated AML Compliance Officer who is responsible for overseeing the implementation and operation of our AML/CTF program. The AML Compliance Officer has the necessary authority, resources, and independence to effectively carry out their responsibilities, which include:

• Developing and implementing AML/CTF policies and procedures
• Monitoring compliance with AML/CTF requirements
• Reviewing and investigating suspicious activities
• Filing suspicious activity reports with the appropriate authorities
• Providing guidance and training to employees on AML/CTF matters
• Reporting regularly to senior management and the Board of Directors

3.3 Internal Controls and Procedures

We have established internal controls and procedures designed to ensure compliance with AML/CTF requirements, including:

• Written policies and procedures that clearly define roles, responsibilities, and processes
• Approval processes for high-risk clients and transactions
• Record-keeping systems that maintain all necessary documentation
• Internal reporting mechanisms for suspicious activities
• Regular independent reviews and audits of our AML/CTF program
• Ongoing monitoring and testing of our controls

3.4 Employee Training

We provide comprehensive AML/CTF training to all employees, with additional specialized training for employees in high-risk roles. Our training program covers:

• The nature and process of money laundering and terrorist financing
• Legal and regulatory requirements
• Our AML/CTF policies and procedures
• How to identify and report suspicious activities
• The consequences of non-compliance

Training is provided at the time of hiring and on an ongoing basis to ensure that employees remain aware of their responsibilities and are updated on new developments in AML/CTF requirements.

3.5 Independent Testing

We conduct regular independent testing of our AML/CTF program to assess its effectiveness and identify areas for improvement. This testing is performed by qualified individuals who are independent of the functions being tested and have sufficient knowledge of AML/CTF requirements.

The results of independent testing are reported to senior management and the Board of Directors, and any identified deficiencies are promptly addressed through appropriate corrective actions.

4. Customer Due Diligence (CDD)

We conduct appropriate customer due diligence before establishing a business relationship with any client and on an ongoing basis throughout the relationship. Our CDD procedures include:

4.1 Client Identification and Verification

We identify and verify the identity of our clients using reliable, independent source documents, data, or information. This includes:

• For individuals: full name, date of birth, address, and identification number
• For legal entities: name, legal form, address, directors, and ownership structure

We verify this information using government-issued identification documents, certified corporate documents, and other reliable sources as appropriate.

4.2 Beneficial Ownership Identification

For legal entities, we identify and verify the identity of beneficial owners, defined as individuals who ultimately own or control the entity. This includes:

• Individuals who own, directly or indirectly, 25% or more of the entity
• Individuals who exercise control over the entity through other means
• Senior managing officials, if no individual meets the ownership or control criteria

4.3 Purpose and Nature of the Relationship

We obtain information about the purpose and intended nature of the business relationship, including:

• The reason for opening the account
• The expected type, volume, and frequency of transactions
• The source of funds and wealth
• The client's occupation or business activities

4.4 Ongoing Monitoring

We conduct ongoing monitoring of our client relationships to ensure that the transactions are consistent with our knowledge of the client, their business, and risk profile. This includes:

• Reviewing and updating client information periodically
• Monitoring transactions for unusual or suspicious patterns
• Reassessing the client's risk profile as needed

5. Enhanced Due Diligence (EDD)

We apply enhanced due diligence measures for higher-risk clients, including:

5.1 Politically Exposed Persons (PEPs)

We have procedures to identify whether a client or beneficial owner is a politically exposed person (PEP), defined as an individual who is or has been entrusted with a prominent public function, as well as their family members and close associates.

For PEPs, we apply enhanced due diligence measures, including:

• Obtaining senior management approval for establishing or continuing the business relationship
• Taking reasonable measures to establish the source of wealth and source of funds
• Conducting enhanced ongoing monitoring of the business relationship

5.2 High-Risk Jurisdictions

We apply enhanced due diligence measures for clients from high-risk jurisdictions, including:

• Countries identified by the FATF as having strategic AML/CTF deficiencies
• Countries subject to sanctions, embargoes, or similar measures
• Countries identified as having significant levels of corruption or other criminal activity
• Countries identified as providing funding or support for terrorist activities

5.3 High-Risk Business Activities

We apply enhanced due diligence measures for clients engaged in high-risk business activities, including:

• Cash-intensive businesses
• Money service businesses
• Casinos and gambling operations
• Arms dealers
• Real estate transactions involving high-value properties
• Dealers in precious metals, stones, or other high-value goods

5.4 Complex Ownership Structures

We apply enhanced due diligence measures for clients with complex ownership structures, including:

• Multiple layers of ownership
• Use of nominee shareholders or directors
• Involvement of trusts, foundations, or similar legal arrangements
• Ownership or control through offshore entities

6. Transaction Monitoring

We monitor client transactions on an ongoing basis to detect suspicious activities. Our transaction monitoring system is designed to identify:

• Transactions that are inconsistent with the client's profile or past behavior
• Transactions that appear to have no legitimate business purpose
• Transactions that may be structured to evade reporting requirements
• Transactions involving high-risk jurisdictions or sanctioned parties
• Unusual patterns of transactions, such as rapid movement of funds
• Large or frequent cash transactions
• Transactions that match known money laundering typologies

When potentially suspicious activities are identified, they are escalated to the AML Compliance Officer for review and investigation.

7. Suspicious Activity Reporting

We report suspicious activities to the appropriate authorities as required by law. Our suspicious activity reporting procedures include:

• Internal reporting mechanisms for employees to report suspicious activities
• Review and investigation of reported activities by the AML Compliance Officer
• Documentation of the decision to file or not file a suspicious activity report
• Timely filing of suspicious activity reports with the appropriate authorities
• Maintaining the confidentiality of suspicious activity reports

We prohibit "tipping off," which means informing a client or any other person that a suspicious activity report has been filed or that an investigation is underway.

8. Record Keeping

We maintain records of all client information, transactions, and compliance activities as required by law. Our record-keeping practices ensure that we can:

• Demonstrate compliance with AML/CTF requirements
• Reconstruct individual transactions
• Respond to requests from regulatory authorities in a timely manner
• Support suspicious activity investigations and reporting

Records are maintained for a minimum of five years after the end of the business relationship or the date of the transaction, or longer if required by applicable law.

9. Sanctions Compliance

We comply with all applicable sanctions regimes, including those imposed by the United Nations, the European Union, the United States, and other relevant jurisdictions. Our sanctions compliance program includes:

• Screening clients against sanctions lists during onboarding and on an ongoing basis
• Screening transactions against sanctions lists
• Blocking transactions involving sanctioned individuals, entities, or jurisdictions
• Reporting potential sanctions violations to the appropriate authorities
• Training employees on sanctions compliance

10. Cooperation with Regulatory Authorities

We cooperate fully with regulatory authorities in their efforts to combat money laundering and terrorist financing. This includes:

• Responding promptly to requests for information
• Providing complete and accurate information
• Facilitating regulatory examinations and inspections
• Implementing corrective actions as needed

11. Client Responsibilities

Our clients have certain responsibilities under our AML/CTF program, including:

• Providing accurate and complete information during the onboarding process
• Updating their information when changes occur
• Responding to our requests for additional information or documentation
• Complying with our policies and procedures
• Not using our services for illegal purposes

Failure to meet these responsibilities may result in the termination of the business relationship.

12. Contact Information

If you have any questions or concerns about our AML Policy, please contact our AML Compliance Officer at:

AuroraEx Limited
Email: [email protected]