Compliance

KYC, Anti-Money Laundering (AML) Policy and Counter-Terrorist Financing (CTF) Compliance

Introduction

Asset Fusion is committed to the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. We understand the critical importance of preventing our platform from being exploited for money laundering or the financing of terrorist activities. This policy outlines our commitment to AML and CTF compliance and the procedures we have established to meet our regulatory obligations.

Definitions

• Money Laundering: The process of concealing the origins of illegally obtained money.
• Terrorist Financing: The process of providing financial support to terrorist organizations.
• Customer Due Diligence (CDD): The process of verifying the identity of our customers and understanding their business activities.
• Suspicious Transaction Report (STR): A report submitted to authorities when a transaction is suspected to be related to money laundering or terrorist financing.

AML Compliance Officer

Asset Fusion has partnered with and appointed MEMA Consultants (https://www.memaconsultants.com/) as our AML Compliance Officer, responsible for overseeing our AML and CTF compliance program. If you have any concerns or observe suspicious activities, please contact compliance@assetfusion.com.

Risk Assessment

Asset Fusion, together with MEMA Consultants, conducts thorough risk assessments to identify and understand the money laundering risks associated with our activities, products, and services. This enables us to develop a risk-based approach to effectively allocate resources and implement appropriate safeguards.

Customer Due Diligence (CDD)

We have established robust procedures for identifying and verifying the identity of our customers. This includes:

• Understanding the customer's business activities.
• Assessing the customer's risk of money laundering or terrorist financing.
• Implementing enhanced due diligence measures for higher-risk customers.
• Ongoing monitoring of customer accounts for suspicious activities.

Know Your Customer (KYC)

Asset Fusion requires detailed information to understand our customers' backgrounds, the purpose of the relationship, and the source of funds. This includes:

• Verifying the Beneficial Ownership of Legal Entities and High Net Worth Individuals: Ensuring that we have clear and accurate information about the ultimate beneficial owners of legal entities and individuals with significant financial resources.
• Retail Investor Verification: Implementing procedures to verify the identity of retail investors, ensuring they are who they claim to be. This includes:
  • Collecting and verifying personal identification documents, such as government-issued ID and proof of address.
  • Cross-referencing information with reliable and independent sources to validate the investor’s identity.
• Purpose and Source of Funds: Understanding the purpose of the relationship with Asset Fusion and the source of the funds being invested. This includes:
  • Assessing the financial background and investment goals of retail investors.
  • Requiring detailed information on the origin of the funds to ensure they are not derived from illicit activities.
• Risk Assessment for Retail Investors: Evaluating the risk profile of retail investors based on factors such as geographical location, investment behavior, and financial history. Higher-risk investors are subject to enhanced due diligence measures.
• Ongoing Monitoring: Continuously monitoring retail investor accounts and transactions to identify any unusual or suspicious activities. This includes regular reviews and updates of customer information to ensure it remains current and accurate.

Suspicious Activity & Transaction Reporting (SATR)

We have established clear procedures for employees to report suspicious activities internally. The process includes:

• Filing Suspicious Activity Reports (SARs) with the appropriate authorities as necessary.
• Ensuring all reported activities are thoroughly investigated and documented.

Transaction Monitoring

Asset Fusion utilizes advanced systems to monitor transactions and detect unusual or suspicious patterns. Our process includes:

• Investigating flagged transactions.
• Resolving potential AML concerns promptly and effectively.

AML Training

We provide regular AML training for all employees, ensuring they are well-informed about AML regulations and their role in maintaining compliance. All training sessions are documented, and attendance records are maintained.

Record Keeping

Asset Fusion maintains stringent record-keeping requirements for customer information, transactions, and AML compliance-related documentation. Records are retained in accordance with regulatory requirements.

Sanction Compliance

We have established procedures for complying with international sanctions programs. Our processes include:

• Regularly screening customers and transactions against relevant sanctions lists.

Third-Party Due Diligence

MEMA Consultants perform regular audits of our AML/CTF program on behalf of Asset Fusion. These independent audits assess the program's effectiveness and identify any areas for improvement.

Internal Controls and Reporting

We have developed robust internal controls to ensure compliance with our AML policy. Regular reports are submitted to senior management and the Board of Directors to ensure ongoing oversight and accountability.

Monitoring and Review

Our AML and CTF compliance program undergoes regular monitoring and review. We periodically evaluate the program to ensure its effectiveness in meeting our regulatory obligations.

Non-Retaliation

Asset Fusion assures employees that they will not face retaliation for reporting suspicious activities or potential AML violations. We encourage proactive reporting to maintain the integrity of our compliance program.

Penalties for Non-Compliance

Non-compliance with our AML policy can result in disciplinary actions, including termination of employment and potential legal consequences.

Disclaimer

This policy does not create any legally binding obligations between Asset Fusion and its employees or users. While Asset Fusion strives to maintain the highest standards of AML and CTF compliance, we do not guarantee that our AML/CTF program will prevent all instances of money laundering or terrorist financing. Employees are responsible for adhering to the policy and reporting any suspected violations to their supervisor.

Conclusion

Asset Fusion is dedicated to upholding the highest standards of AML and CTF compliance. This policy provides a clear framework for our employees to follow, ensuring we meet our obligations and maintain the trust of our investors and stakeholders.