a& Capital Legal Information

AML Policy

This Anti-Money Laundering and Counter-Terrorism Financing Policy serves as a foundational guideline for A and Capital Ltd ., herein referred to as "the Company." It is meticulously crafted to ensure adherence to applicable legal and regulatory frameworks enforced by the Comoros Mwali International Service Authority (M.I.S.A.) on the Autonomous Island of Mwali (Mohéli), along with other relevant international standards.

Our objective is to preempt, identify, and actively counteract efforts aimed at money laundering and terrorism financing. The leadership of A and Capital Ltd . deeply values the role it plays in identifying and disrupting financial support networks for criminal activities. We, along with our affiliates, steadfastly refuse to facilitate or engage in money laundering or any actions that could indirectly support terrorist or criminal endeavors.

Definitions

Transaction: This term encompasses all financial activities including deposits, withdrawals, fund transfers, and exchanges carried out by our clients.

Money Laundering: Defined as the process of disguising illegal profits to make them appear legitimate. This involves transforming criminally derived gains into seemingly legal assets, effectively masking the origins and reducing the visibility of large sums accrued through illicit means, such as tax evasion, corruption, drug trafficking, and more.

Money laundering typically occurs in three stages:

• Placement: Illicit funds are initially introduced into the financial system through various means.

• Layering: Funds are moved and diversified through multiple transactions to distance them from their criminal origins.

• Integration: Finally, the laundered money is reintegrated into the economy, appearing as legitimate business earnings or investments.

Terrorist Financing: Unlike money laundering, terrorist financing may not always stem from criminal proceeds but focuses on obscuring the origin or intended use of the funds to support criminal activities.

Risk-Based Approach

A and Capital Ltd . recognizes the inherent risks of being exploited for money laundering and terrorist financing. Identifying, evaluating, and mitigating these risks are integral to our broader strategy for managing business-related risks. By thoroughly understanding our clients and their financial activities, we can effectively identify and investigate suspicious transactions. This risk-based approach enables us to allocate resources efficiently, reducing compliance costs and minimizing inconvenience to our clients while adapting to evolving risks.

Anti-Money Laundering Reporting Officer (MLRO)

The Company will appoint a dedicated MLRO, who possesses the requisite experience, knowledge, and training to oversee our AML/CFT program. This officer will be accountable for monitoring compliance, managing communication and training, maintaining records, and filing Suspicious Transaction Reports (STRs) as necessary. The MLRO's responsibilities also include ensuring the implementation of effective customer identification and verification processes.

Suspicious Transaction Reports (STRs)

STRs are confidential and only disclosed to the MLRO. The filing of an STR provides protection against civil, criminal, or disciplinary actions, provided the information was not disclosed in bad faith. All STR records must be maintained for a minimum of seven years.

=Customer Due Diligence (CDD)

CDD is crucial for managing money laundering and terrorist financing risks. It involves identifying and verifying clients' identities using reliable, independent sources. This process is conducted at the outset of the business relationship and periodically thereafter. A and Capital Ltd . will collect and verify identification information from customers, tailoring verification measures based on the risk profile and ensuring records of customer identification and verification methods are meticulously kept.

Enhanced Due Diligence (EDD)

EDD is applied in situations where there is a higher risk of money laundering or terrorist financing. This may involve clients from high-risk countries, or those attempting to conduct complex or unusually large transactions. EDD measures include obtaining information on the source of funds or wealth and conducting more rigorous ongoing monitoring.

Politically Exposed Persons (PEPs)

A and Capital Ltd . will take steps to identify and apply EDD measures to PEPs, ensuring the source of their funds and wealth is understood and monitored closely. Business relationships with PEPs will only be established or continued with senior management's approval.

Monitoring Accounts for Suspicious Transactions

The Company will monitor account activities to identify unusual patterns that may indicate money laundering or terrorist financing. This includes transactions over USD 10,000 or equivalent. The MLRO is responsible for this monitoring and reporting suspicious transactions to the appropriate authorities.

Record Keeping

A and Capital Ltd . will maintain detailed records of fund transfers, including the recipient's name and address, amount transferred, recipient's financial institution, and account number. This information will be kept to facilitate any future investigations by authorities.

By implementing this comprehensive Anti-Money Laundering and Counter-Terrorism Financing Policy, A and Capital Ltd . reaffirms its commitment to upholding the highest standards of financial integrity and compliance with the regulatory frameworks enforced by the Comoros Mwali International Service Authority (M.I.S.A.) on the Autonomous Island of Mwali (Mohéli).