1. INTRODUCTION

MMTECH SOLUTIONS LIMITED ("the Company") is committed to complying with all applicable Anti-Money Laundering (AML), Counter Financing of Terrorism (CFT), and Know Your Customer (KYC) regulations in Saint Lucia. This policy outlines our framework for preventing money laundering, terrorist financing, and ensuring compliance with the Money Laundering (Prevention) Act of Saint Lucia and international best practices such as the Financial Action Task Force (FATF) recommendations.

This Policy shall undergo periodic reviews to maintain its effectiveness and ensure continued compliance with the evolving regulatory and legal frameworks in Saint Lucia.

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2. PURPOSE

This Anti-Money Laundering (AML), Counter Financing of Terrorism (CFT), and Know Your Customer (KYC) Policy (the “Policy”) is established to outline the framework, principles, and measures adopted by the Company to prevent, detect, and mitigate the risks associated with money laundering, terrorist financing, fraud, and other financial crimes. This Policy ensures compliance with applicable laws and regulations in Saint Lucia, including but not limited to the Money Laundering (Prevention) Act, the Counter-Terrorism Act, and guidelines issued by the Financial Services Regulatory Authority (FSRA) of Saint Lucia, as well as international standards such as the Financial Action Task Force (FATF) Recommendations.

The objectives of this Policy are to:

• Compliance with Legal and Regulatory Requirements
• Know Your Customer (KYC)
• Risk Assessment and Management
• Record-Keeping and Retention
• Suspicious Transaction Monitoring and Reporting
• Employee Training and Awareness

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3. REGULATORY FRAMEWORK

This Policy is developed in full compliance with the legal and regulatory framework governing financial crimes in Saint Lucia and internationally. It establishes a structured approach to ensure adherence to regulatory requirements, mitigate associated risks, and enhance transparency in financial transactions.

The key regulatory instruments that guide the implementation of this policy include, but are not limited to, the following:

1. The Money Laundering (Prevention) Act of Saint Lucia.

2. Other Applicable Laws and International Standards.

This policy also considers other relevant national and international legal frameworks, such as:

• The Counter-Terrorism Act of Saint Lucia, which establishes measures to combat terrorist financing and prevent the misuse of financial institutions for terrorist activities.
• The Proceeds of Crime Act, which provides for the confiscation and recovery of assets derived from criminal conduct, including money laundering offenses.
• The International Financial Services Act, which regulates offshore financial institutions and ensures compliance with AML/CFT obligations within the offshore financial sector.
• United Nations (UN) Conventions and Resolutions, including obligations to comply with targeted financial sanctions and measures to prevent the financing of terrorism.
• United States Office of Foreign Assets Control (OFAC) sanctions compliance, where applicable to transactions involving U.S. persons or interests.
• European Union (EU) AML Directives, where applicable to cross-border operations involving EU-based entities or financial transactions.

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4. KNOW YOUR CUSTOMER (KYC)

The Company’s Know Your Customer (KYC) framework is implemented to ensure full compliance with applicable Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT) regulations. This framework aims to mitigate the risks of financial crimes by verifying customer identities, understanding their financial activities, and assessing the potential risks associated with business relationships.

4.1 Identification and Verification

The Company implements a comprehensive identification and verification process tailored to the specific nature of each customer, whether an individual or an entity, to accurately establish their identity.

For Individuals:
The following documents and information are required to verify an individual’s identity and assess their financial profile:

• Government-issued Identification: A valid passport, national ID card, or driver’s license.
• Proof of Address: Recent utility bills, bank statements, or government-issued correspondence (dated within the last three months).
• Financial Statements: Income records, employment details, or bank statements to assess financial standing and source of funds.

For Corporate Entities:
To verify the legitimacy and ownership structure of corporate entities, the following documents and information are required:

• Certificate of Incorporation: A legal document that proves the entity's registration and existence under the law.
• Ownership Structure: A detailed breakdown of the shareholding structure, including ultimate beneficial owners (UBOs) holding 25% or more of the shares.
• Authorized Signatories: A list of individuals authorized to act on behalf of the company, supported by board resolutions and identification documents.
• Memorandum and Articles of Association:
• Tax Identification Number (Where applicable).

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5. RISK-BASED APPROACH

The company applies a risk-based approach to customer due diligence, categorizing customers into low-risk and high-risk profiles based on various risk factors, including geographic location, nature of business, transaction patterns, and regulatory exposure.

Low-Risk Customers:

• Subject to standard CDD measures, which include verifying identity, establishing the nature of business relationships, and monitoring account activity.
• Typical examples include salaried employees, small retail businesses, and clients from low-risk jurisdictions.

High-Risk Customers:

• Subject to enhanced due diligence (EDD), which involves gathering additional information to fully assess potential risks.
• High-risk customers include politically exposed persons (PEPs), customers from high-risk jurisdictions, and businesses dealing in cash-intensive operations.
• Additional verification may involve background checks, detailed scrutiny of source of funds, and obtaining additional references.

5.1. Enhanced Due Diligence (EDD)

For customers identified as high risk, the company implements enhanced due diligence measures to mitigate potential financial crime risks. These measures include:

• Source of Funds and Wealth Verification.
• Enhanced Monitoring of Transactions.
• Senior Management Approval.
• Increased Frequency of Reviews

5.2. Politically Exposed Persons (PEPs)

Politically exposed persons (PEPs), their family members, and close associates pose a heightened risk due to their potential exposure to bribery, corruption, and illicit financial activities. The company adopts a comprehensive approach to managing PEP relationships, including:

• Screening customers against PEP databases, international sanctions lists, and watchlists to identify potential exposure.
• Evaluating the level of risk associated with the PEP’s position, the country of residence, and the nature of their financial transactions.
• Applying stricter verification processes, such as obtaining additional references, conducting in-depth background checks, and verifying the legitimacy of their funds.
• Conducting frequent and thorough reviews of transactions involving PEPs to detect unusual or suspicious activity.
• Prior approval from senior executives is required before establishing or continuing relationships with PEPs.

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6. RECORD KEEPING

As a company, we ensure that all data is securely stored, easily retrievable, and protected against unauthorized access, alteration, or destruction.

The Company shall maintain the following records in accordance with applicable regulatory requirements:

6.1 Customer Identification Data

• All customer identification documents and verification data, and any other supporting documentation obtained during the customer onboarding process.
• These records shall be retained for a minimum of five (5) years after the termination of the business relationship or from the completion of the last transaction, whichever is later.
• Customer records will be stored in encrypted digital formats to ensure data integrity and confidentiality, with access restricted to authorized personnel only.

6.2 Transaction Records

• The Company shall maintain detailed records of all transactions conducted with customers, including payment history, transaction amounts, timestamps, and counterparties involved.
• These records will include both financial and non-financial transactions relevant to the Company's services, such as software licensing purchases, cloud service subscriptions, and IT consultancy payments.
• Transaction records will be retained for a minimum of five (5) years, as stipulated by regulatory authorities, to facilitate compliance audits and investigations.

6.3 Disposal of Records

• Upon expiration of the mandatory retention period, records shall be securely disposed of in compliance with data protection laws and company policies.
• Electronic records will be permanently deleted using certified data erasure tools, while physical records will be shredded or incinerated under supervision.

7. TRANSACTION MONITORING AND REPORTING TO REGULATORY AUTHORITIES

The company has established clear procedures for identifying and reporting suspicious activities in compliance with the Money Laundering (Prevention) Act of Saint Lucia and relevant regulatory guidelines. The reporting process will include:

• Detection and Escalation: Once an alert is triggered by the automated monitoring system, the compliance team will conduct a detailed analysis to determine whether the transaction requires further reporting.
• Internal Reporting Mechanism: Employees will be trained to identify and internally report any suspicious activities they encounter in their day-to-day operations.
• Filing SARs with Authorities: If a transaction is deemed suspicious, the company will submit a Suspicious Activity Report (SAR) to the Financial Intelligence Authority (FIA) within the required timeframe, ensuring all necessary details are provided, including:
  • The nature and details of the suspicious transaction.
  • Customer identification information.
  • Transaction history and relevant supporting documentation.
• Confidentiality and Non-Disclosure: The SAR process will be handled with utmost confidentiality, ensuring that the reported party is not made aware of the investigation.
• Record-Keeping: The company will maintain records of all filed SARs and related documentation for a minimum period as required by law, ensuring accessibility for regulatory audits.
• Periodic Review and Training: Regular reviews of SARs and training for relevant employees to improve their ability to recognize and report suspicious activities effectively.

8. EMPLOYEE TRAINING AND AWARENESS

The Company is committed to fostering a culture of compliance by ensuring that all employees, particularly those in sensitive roles, receive ongoing training and awareness programs related to Anti-Money Laundering (AML) and Know Your Customer (KYC) obligations. The goal is to equip employees with the necessary knowledge and skills to identify, prevent, and report potential financial crimes in accordance with regulatory requirements and industry best practices.

The primary objectives of the AML/KYC training program are to:

• Ensure employees understand their legal and regulatory obligations under the Money Laundering (Prevention) Act of St. Lucia and other applicable regulations.
• Educate staff on how to detect, prevent, and report suspicious activities.
• Reinforce the importance of customer due diligence (CDD) and enhanced due diligence (EDD) measures.
• Enhance employees’ ability to recognize red flags associated with money laundering and terrorism financing.
• Promote adherence to the Company's internal policies and procedures.

9. POLICY REVIEW AND UPDATES

This policy will be reviewed annually or as required by changes in laws and regulations. Updates will be approved by senior management to ensure continued compliance and effectiveness.

10. NON-COMPLIANCE CONSEQUENCES

Failure to comply with this policy may result in disciplinary action, including termination of services or legal actions as deemed necessary.

11. CONCLUSION

MMTECH SOLUTIONS LIMITED is committed to the highest standards of regulatory compliance and ethical business conduct. Our AML, CFT, and KYC policies serve as a foundation for safeguarding our operations and maintaining trust with stakeholders. Our internal procedures offer more detailed guidance on these principles, and this policy should not be interpreted as exhaustive or unalterable.

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