3. KYC REQUIREMENTS

3.1. Customer Acceptance Policy (“CAP”) is covered in Annexure 1.

3.2. Customer Identification Procedures (“CIP”) are given in Annexure 2.

3.3. CDD Procedures are provided in Annexure 3.

3.3.1. KYC Recording Procedure:

The Company will collect KYC data for storage in the KYC Register, following the KYC templates designated for 'individuals' and 'Legal Entities' as appropriate, and as periodically revised.

The Company will upload, or update KYC information related to individual customer accounts during scheduled updates or sooner upon receipt of updated KYC data from the customer.

Refer to Annexure 3 for a detailed CDD procedure.

3.4. Record Management is covered in Annexure 4.

3.5. Risk Management is covered in Annexure 5.

3.6. Enhanced Due Diligence (EDD) measures are covered in Annexure 6

3.7. Appointment of Principal Officer:

The Company will designate a Money Laundering Compliance Officer (MLCO), tasked with overseeing and reporting on all transactions and information-sharing obligations mandated by law. The MLCO will establish and maintain strong connections with law enforcement agencies, financial institutions, and any other relevant entities engaged in efforts to combat money laundering and terrorism financing.

3.8. Appointment of Designated Director:

The Company shall appoint a Designated Director in terms of the obligations under the applicable laws.

3.9. Ongoing Due Diligence:

The Company shall conduct continuous due diligence on customers to ensure that their transactions align with the Company's understanding of the customers, their business activities, risk profile, and the source of funds, including cash or wealth.

The extent of transaction monitoring will be tailored according to the account's risk profile. The Company will strive to comprehend the typical customer activity to identify transactions deviating from the norm. Special attention will be devoted to complex, unusually large transactions, and patterns devoid of apparent economic or lawful purpose. The Company will adhere to a management-approved standard operating procedure (SOP) to classify cases as High, Medium, or Low Risk.

Appropriate thresholds will be established based on customer risk categorization to ensure heightened monitoring. When reviewing alerts, attention will be directed toward the customer's background, identity, financial status, business nature, origin country, fund sources, geographical risk, transaction types, products/services offered, and delivery channels.

To adhere to AML/CFT policies, the Company utilizes a client-provided database to screen new account opening applications against designated watch lists. Upon identifying a true match, besides preventing customer onboarding, the Company promptly reports to relevant authorities. Lists are periodically updated, and screening is also conducted during fresh loan disbursement for existing customers. Additionally, the Company will undertake necessary countermeasures when prompted by any international or intergovernmental organization recognized by the Central Government of Anjouan.

Periodic risk assessments are essential to identify, assess, and mitigate money laundering and terrorist financing risks concerning clients, countries, or geographic areas. However, such assessments will not be applicable to the Company, considering relevant risk factors and the overall risk level based on its products, services, transaction size, and delivery channels. The frequency of risk assessment will be determined by the Board or its delegated committee, reviewed at least annually.

The Company will adopt a Risk-Based Approach (RBA) for mitigating and managing identified risks, implementing a Customer Due Diligence (CDD) program tailored to the identified AML/CFT risks and business size. Moreover, the Company will monitor control implementation and enhance them as necessary during risk assessment reviews.

3.10. Reporting of Transactions:

Further, the Company shall be guided by MLCO advice for necessary actions to be taken, including additional measures (if any) for managing the ML/TF risk(s), for the reporting requirements and procedures based on applicable laws.

3.11. Training Program:

The Company will maintain an ongoing training program for its employees to ensure they possess adequate knowledge of KYC/AML procedures and stay abreast of evolving KYC/AML/CFT regulations both domestically and internationally.

Training initiatives will be tailored to the specific needs of frontline staff, compliance personnel, and individuals handling new customer interactions, ensuring comprehensive understanding and consistent implementation of KYC policies and norms.

3.12. Internal Control System:

The Company's Internal Audit and Compliance functions will assess and ensure adherence to KYC policies and procedures. The compliance function will independently evaluate the Company’s policies, procedures, and compliance with legal and regulatory requirements. Management, overseen by Vinus International Ltd., ensures that internal auditors include KYC procedure review within their scope of work and maintain a proficient team. Internal Auditors will specifically examine and verify KYC procedure applications at branches, highlighting any observed deficiencies. Audit findings and compliance will be presented to the Audit Committee annually.

Furthermore, the Company will establish a rigorous screening mechanism as an integral part of its personnel recruitment process to prevent individuals with criminal backgrounds from accessing and potentially exploiting financial channels.

MLCO (Money Laundering Compliance Officer) after obtaining the due approval from the Board shall make the necessary amendments/modifications in this Policy or such other related guidance notes of the Company, to be in line with statutory authority’s requirements/updates/ amendments from time to time.

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