AML & KYC Policy

Introduction

MSB Financial Ltd ("MSB") is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines our approach to compliance with applicable financial crime regulations.

This is a template document for development purposes only. It must be reviewed by qualified legal counsel before use in a production environment.

Regulatory Framework

We operate in accordance with applicable AML and financial crime legislation, including:

• The Proceeds of Crime Act 2002 (POCA)
• The Terrorism Act 2000
• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017)
• FATF (Financial Action Task Force) Recommendations
• Any other applicable jurisdiction-specific requirements

Know Your Customer (KYC)

Customer Due Diligence (CDD)

Before providing services, we collect and verify information about our customers to establish their identity and understand the nature of their intended business relationship with us.

Standard CDD requires:

• Full legal name
• Date of birth
• Residential address
• Nationality and country of residence
• Government-issued photo identification (passport, national ID card)
• Proof of address (utility bill, bank statement — not older than 3 months)

Enhanced Due Diligence (EDD)

For higher-risk customers, we apply Enhanced Due Diligence, which may include:

• Additional identity documents
• Source of wealth and source of funds documentation
• Enhanced monitoring of transactions
• Senior management approval

EDD is applied where we identify higher risk factors, including but not limited to: Politically Exposed Persons (PEPs), high-risk countries, complex ownership structures, or unusual transaction patterns.

Simplified Due Diligence (SDD)

In limited circumstances prescribed by regulation, we may apply Simplified Due Diligence for lower-risk customers and products.

Ongoing Monitoring

We continuously monitor customer transactions and activity to detect unusual patterns that may indicate money laundering, fraud, or other financial crime. This includes:

• Transaction monitoring against defined thresholds and patterns
• Screening against international sanctions lists (OFAC, UN, EU, HMT)
• Periodic reviews of customer risk profiles
• Monitoring of Politically Exposed Persons (PEPs) and their associates

Suspicious Activity Reporting

Where we identify suspicious activity, we are required by law to file a Suspicious Activity Report (SAR) with the relevant authority (in the UK, the National Crime Agency). We will not "tip off" customers about SAR filings.

Sanctions Compliance

We screen all customers and transactions against applicable sanctions lists. Where a match is identified, we will freeze the relevant account or transaction and take appropriate action in accordance with legal requirements.

Record Keeping

We retain AML/KYC records for a minimum of 5 years from the date of the last transaction or the date of account closure, whichever is later, as required by applicable regulations.

Training

All relevant staff receive regular AML/KYC training. We maintain a culture of compliance throughout our organisation.

Reporting Obligations

We report to the relevant regulatory authorities as required, including:

• Suspicious Activity Reports (SARs)
• Threshold transaction reports where applicable
• Regulatory returns and compliance certifications

Risk Assessment

We maintain a documented firm-wide risk assessment that is reviewed and updated regularly to reflect changes in our products, customers, geographies, and the broader regulatory landscape.

Senior Management Responsibility

Our Board and senior management are responsible for maintaining an effective AML/KYC framework. Our nominated Money Laundering Reporting Officer (MLRO) oversees day-to-day compliance.

Contact

If you have questions about our AML/KYC obligations or wish to report a concern, please contact our Compliance team at compliance@msb.com.