Anti-Money Laundering (AML) Policy

Policy Reference: AML-MV-2026-001  |  Effective: April 2026  |  Last Updated: April 2026  |  Version: 2.0

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1. Policy Statement

Mallvest is fully committed to complying with all applicable anti-money laundering (AML) and counter-terrorist financing (CTF) laws and regulations in every jurisdiction in which we operate. We have a zero-tolerance policy towards money laundering, terrorist financing, bribery, corruption, and any other financial crime.

We are committed to:

• Compliance: Adhering to all applicable AML/CTF laws, regulations, and international standards in the UK, Ghana, Nigeria, and Côte d'Ivoire.
• Transparency: Maintaining complete transparency in all financial transactions and business activities.
• Due Diligence: Conducting thorough customer due diligence (CDD) and enhanced due diligence (EDD) on all investors, partners, and counterparties.
• Reporting: Promptly reporting any suspicious activity to the relevant Financial Intelligence Units (FIUs) and regulatory authorities.
• Record Keeping: Maintaining accurate and comprehensive records of all transactions, customer identifications, and due diligence processes for the required statutory periods.

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2. Legal & Regulatory Framework

Mallvest's AML Policy is based on and complies with the following laws, regulations, and international standards:

2.1 United Kingdom

• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 — as amended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 and 2022.
• The Proceeds of Crime Act 2002 (POCA) — the primary legislation criminalising money laundering in the UK.
• The Terrorism Act 2000 — legislation criminalising terrorist financing and requiring reporting of suspicious activity.
• Financial Conduct Authority (FCA) Guidance — including the FCA's AML/CTF Handbook and sector-specific guidance.
• Office of Financial Sanctions Implementation (OFSI) — compliance with UK financial sanctions regimes.

2.2 Ghana

• Anti-Money Laundering Act, 2020 (Act 1044) — the principal AML legislation in Ghana.
• Anti-Terrorism Act, 2008 (Act 762) — legislation criminalising terrorist financing.
• Financial Intelligence Centre (FIC) Regulations — guidelines issued by Ghana's Financial Intelligence Centre.
• Bank of Ghana (BoG) Directives — AML/CTF directives issued by the central bank.

2.3 Nigeria

• Money Laundering (Prevention and Prohibition) Act, 2022 — the primary AML legislation in Nigeria.
• Terrorism (Prevention) Act, 2022 — legislation criminalising terrorist financing.
• Nigeria Financial Intelligence Unit (NFIU) Guidelines — AML/CTF regulations issued by the NFIU.
• Securities and Exchange Commission (SEC) Nigeria Rules — AML rules for capital market operators.

2.4 Côte d'Ivoire

• Loi n° 2016-694 du 3 août 2016 — the principal AML legislation in Côte d'Ivoire.
• CENTIF (Cellule Nationale de Traitement des Informations Financières) — the national financial intelligence unit.
• Autorité des Marchés Financiers (AMF) — AML regulations for capital market operations.

2.5 International Standards

• Financial Action Task Force (FATF) — international standards for AML/CTF, including the 40 Recommendations.
• United Nations Conventions — including the UN Convention against Transnational Organized Crime and the UN Convention against Corruption.

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3. Customer Due Diligence (CDD)

Mallvest implements a risk-based approach to customer due diligence. We are required to identify and verify the identity of all investors, partners, and counterparties before establishing a business relationship or conducting any transaction.

3.1 Know Your Customer (KYC) Procedures

Our KYC procedures require the collection and verification of the following information for all investors:

• Full Legal Name: As it appears on official identification documents.
• Date of Birth: To confirm age and legal capacity.
• Residential Address: Current physical address, verified by proof of address (e.g., utility bill, bank statement).
• Government-Issued Identification: Passport, national ID card, or driver's license (front and back).
• Source of Funds: Declaration of the origin of funds used for investment.
• Phone Number & Email Address: For verification and communication purposes.

3.2 Enhanced Due Diligence (EDD)

Enhanced due diligence measures are applied to high-risk investors and transactions, including:

• Politically Exposed Persons (PEPs): Additional verification for individuals holding prominent public positions or their family members and close associates.
• High-Risk Jurisdictions: Investors from countries with known AML deficiencies as identified by FATF.
• Complex Transactions: Transactions that are unusually large, complex, or have no apparent economic purpose.
• Beneficial Ownership: Verification of ultimate beneficial owners for corporate investors and legal entities.

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4. Sanctions Compliance

Mallvest is fully committed to complying with all applicable international sanctions regimes, including:

• UK Sanctions: All sanctions imposed by the UK government through the Office of Financial Sanctions Implementation (OFSI).
• UN Sanctions: All sanctions imposed by the United Nations Security Council.
• EU Sanctions: All sanctions imposed by the European Union (as applicable).
• US Sanctions: All sanctions imposed by the United States Office of Foreign Assets Control (OFAC).

We maintain a robust sanctions screening process to ensure that we do not transact with any individual or entity subject to international sanctions. All investors and counterparties are screened against global sanctions lists prior to establishing a business relationship.

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5. Suspicious Activity Reporting

Mallvest has a legal and moral obligation to report any suspicious activity to the relevant Financial Intelligence Units (FIUs) and regulatory authorities.

5.1 Reporting Obligations

We are required to report:

• Suspicious Transactions: Any transaction that is unusual, complex, or appears to have no legitimate economic purpose.
• Unusual Activity: Any activity that is inconsistent with the known profile or behavior of the investor.
• Sanctions Breaches: Any attempted transaction involving a sanctioned individual or entity.
• Terrorist Financing: Any activity suspected of being linked to terrorist financing.

5.2 Responsible Authorities

Reports are filed with the following authorities, depending on the jurisdiction:

• United Kingdom: National Crime Agency (NCA) — UK Financial Intelligence Unit (UKFIU).
• Ghana: Financial Intelligence Centre (FIC).
• Nigeria: Nigeria Financial Intelligence Unit (NFIU).
• Côte d'Ivoire: CENTIF (Cellule Nationale de Traitement des Informations Financières).

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6. Record Keeping

Mallvest maintains comprehensive records of all transactions, customer identifications, and due diligence processes in accordance with applicable laws and regulations.

• Retention Period: All records are retained for a minimum of 5 years after the end of the business relationship or the completion of a transaction, in accordance with UK and West African regulatory requirements.
• Transaction Records: All transaction details, including amounts, parties involved, dates, and purpose of transactions, are recorded and stored securely.
• KYC Records: All identification documents and verification records are stored securely and confidentially.
• Training Records: Records of all AML training provided to staff are maintained.
• Reporting Records: Copies of all suspicious activity reports filed with regulatory authorities are retained.

All records are stored securely, with access restricted to authorized personnel only.

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7. AML Compliance Officer

Mallvest has appointed a designated AML Compliance Officer who is responsible for overseeing and enforcing this AML Policy.

The AML Compliance Officer is responsible for:

• Policy Implementation: Ensuring that this AML Policy is effectively implemented and enforced across the organization.
• Training: Providing AML training to all staff and ensuring ongoing awareness of regulatory obligations.
• Monitoring: Monitoring compliance with AML/CTF regulations and reporting to the Board of Directors.
• Reporting: Filing suspicious activity reports with the relevant FIUs.
• Review: Conducting regular reviews of the AML Policy and recommending updates as necessary.

All AML-related inquiries, concerns, and suspicious activity reports should be directed to the AML Compliance Officer:

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8. Staff Training

Mallvest is committed to ensuring that all staff are adequately trained in AML/CTF compliance. All employees receive comprehensive training on:

• AML/CTF Regulations: An overview of applicable laws and regulations in the UK, Ghana, Nigeria, and Côte d'Ivoire.
• Red Flags: Identification of suspicious activity and money laundering red flags.
• KYC Procedures: Proper implementation of Know Your Customer procedures and verification processes.
• Reporting Obligations: Understanding of reporting obligations and the procedures for filing suspicious activity reports.
• Sanctions Awareness: Understanding of international sanctions regimes and the prohibition on transacting with sanctioned individuals or entities.

Training is provided upon hiring and on an ongoing basis to ensure that all staff remain informed of evolving regulatory requirements and emerging risks.

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9. Policy Review & Update

This AML Policy is subject to regular review and update to ensure that it remains compliant with evolving regulatory requirements and industry best practices.

• Annual Review: The AML Policy is reviewed annually by the AML Compliance Officer and the Board of Directors.
• Regulatory Updates: The policy is updated promptly whenever there are changes to applicable laws or regulations.
• Risk Assessment: Regular risk assessments are conducted to identify and mitigate potential AML/CTF risks.
• External Audit: The AML Policy and compliance program are subject to independent external audits to ensure effectiveness and integrity.

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10. Contact Information

For any questions or concerns regarding this AML Policy, or to report suspicious activity, please contact:

AML Compliance Officer: Mallvest AML Team

Email: aml@mallvest.com

Support Ticket: Available via your Mallvest dashboard.

Operational Headquarters: Sampa, Bono Region, Ghana

UK Registered Office: Suite 11, Enterprise House, Meadowfield Avenue, Spennymoor, England, DL16 6JF

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Mallvest — Anti-Money Laundering (AML) Policy

Version 2.0 | April 2026