Anti-Money Laundering & Combatting the Financing ofTerrorism Policy(Last updated: March 2024)

This document is property of Axiory Global Ltd. The reproduction in whole or in part inany way including the reproduction in summary form, the reissue in a different mannerand any changes in the original document or any translated version is strictly forbidden
without the prior specific permission of Axiory Global Ltd.

Axiory Global Ltd. is licensed and regulated by the FSC Belize Registration. No 000122/8.

POLICY STATEMENT
Axiory Global Ltd (the “Company”) is committed to providing excellent service to its customers
while ensuring compliance with all regulatory requirements. One of the key components of theCompany’s compliance programme is its Anti-Money Laundering & Combatting the Financingof Terrorism Policy (the “Policy”), which outlines the procedures and processes for identifying
and verifying the identity of new customers, conducting customer due diligence checks, andassessing the risk of each customer.
To achieve this goal, the Company has established this Policy that will define the principles andarrangements to be employed by the Company for it to conduct its business with due skill, careand diligence, in order to mitigate the risk of financial crime, including money laundering andterrorist financing, and to protect the integrity of the Company and the wider financial system.
By implementing this Policy, the Company aims to build trust with its customers anddemonstrate its commitment to ethical business practices.

Axiory Global Ltd. is licensed and regulated by the FSC Belize Registration No. 000122/08.

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TABLE OF CONTENTSI.

INTRODUCTION AND PURPOSE ....................................................................................................... 4II.

SCOPE .............................................................................................................................................. 4

III.

COMPLIANCE WITH THIS POLICY ..................................................................................................... 4

IV. RISK ASSESSMENT ........................................................................................................................... 5V.

CUSTOMER DUE DILIGENCE ............................................................................................................ 5

VI. ONGOING MONITORING ................................................................................................................. 8VII. EMPLOYEE SCREENING.................................................................................................................... 9
VIII. ANTI-MONEY LAUNDERING COMPLIANCE OFFICER ........................................................................ 9
IX. INDEPENDENT AUDIT ...................................................................................................................... 9X.

TRAINING....................................................................................................................................... 10

XI. REVIEW OF THIS POLICY ................................................................................................................ 10
XII. APPROVAL OF THIS POLICY ............................................................................................................ 10

Axiory Global Ltd. is licensed and regulated by the FSC Belize Registration No. 000122/08.

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I.

INTRODUCTION AND PURPOSE

The purpose of this Policy is to summarize the approach and internal practice, measures,procedures, and controls relevant to the prevention of Money Laundering and Terrorist
Financing of the Company.
The Company shall ensure the policies and procedures established include systems andcontrols that:(a) enable it to identify, assess, monitor and manage money laundering and terrorist financing(“ML-TF”) risk; and(b) are comprehensive and proportionate to the nature, scale and complexity of its activities.
To prevent ML-TF, the Company shall comply with anti-money laundering and counterterrorism financing (“AML-CFT”) laws, verify the identity of customers, and assist government
agencies and financial organizations working to combat money laundering.
The Belize AML-CFT legislative framework consists of the following legislations:▪
▪

Money Laundering and Terrorism (Prevention) Act 2020, as amended by the Money
Laundering and Terrorism (Prevention) (Amendment) Act 2023
Financial Intelligence Unit Act 2014

Additionally, the Company follows the recommendations of the Financial Action Task Force(“FATF”), which is an independent inter-governmental body that develops and promotes
policies to protect the global financial system against ML-TF and the financing of theproliferation of weapons of mass destruction. The FATF Recommendations are recognised as
the global standards in respect of AML-CFT.
II.

SCOPE

This Policy applies to the Company, all of its staff, contractors, vendors, and any otherindividuals who interact with the Company in the course of their business activities.
III. COMPLIANCE WITH THIS POLICYAll of the Company’s staff, contractors, vendors, and any other individuals who interact with
the Company in the course of their business activities, must have knowledge of, and comply
with, this Policy. Failure to comply with this Policy may result in disciplinary action as
appropriate.
The Company recognizes that failure to comply with this Policy could lead to legal or regulatory
actions against the Company, its directors, shareholders, staff, and agents. Therefore, theCompany emphasizes the importance of strict adherence to this Policy in order to prevent
fraudulent activities and maintain the integrity of its operations.

Axiory Global Ltd. is licensed and regulated by the FSC Belize Registration No. 000122/08.

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IV. RISK ASSESSMENT

The Company has a duty to identify, assess and understand its ML-TF risks, and establish
policies, controls and procedures to mitigate and manage effectively the risks identified in any
risk assessment taken by the Company. In this respect, the Company should:(a) understand its ML-TF risks; and(b) have in place effective policies, procedures and controls to:(i) identify(ii) assess(iii) understand(iv) mitigate(v) manage, and(vi) review and monitor those risks in a way that is consistent with the AML-CFT
requirements and this Policy.
The Company adopts a risk-based approach to managing ML-TF risks and determining:(a) appropriate levels of customer due diligence measures, including whether to apply
enhanced due diligence measures;(b) mitigation measures commensurate with the risks posed by the Company’s customers,
business relationships, countries or geographic areas, services, delivery channels,
products and transactions;(c) measures for detecting and reporting suspicious activity; and(d) whether and how to launch new products, services or technologies.
The Company shall manage its ML-TF risks in an analytical and considered way and establish
and maintain policies, procedures and controls that are specific, appropriate andproportionate to the risks its senior management identifies. Risk assessments shall be
documented, kept up-to-date and approved by senior management.
The Company recognises that policies, procedures and controls may not always prevent anddetect ML-TF. Nevertheless, a risk-based approach allows the Company to balance the cost of
AML-CFT compliance resources with a realistic assessment of the risk of the Company being
used in connection with ML-TF. A risk-based approach focuses resources and efforts where
they are needed and where they have the greatest impact.
V.

CUSTOMER DUE DILIGENCE

The Company shall apply Customer Due Diligence (“CDD”) measures to a customer when it:(a) establishes a business relationship with the customer;(b) carries on an occasional transaction for the customer;(c) suspects the customer of money laundering or terrorist financing; and(d) doubts the veracity or adequacy of documents, data or information previously obtained
for the purpose of identifying, or verifying the identity of, the customer.

Axiory Global Ltd. is licensed and regulated by the FSC Belize Registration No. 000122/08.

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The CDD measures that must be carried out involve:(a) identifying the customer, and verifying his identity;(b) identifying the beneficial owner, where relevant, and verifying his identity;(c) assessing, and where appropriate obtaining information on, the purpose and intended
nature of the business relationship or transaction.
Where the beneficial owner is a legal person, the Company must take reasonable measures tounderstand the ownership and control structure of that legal person.
For some business relationships, determined by the Company to present a low degree of risk
of ML-TF, simplified due diligence (SDD) may be applied; in the case of high-risk situations, andspecifically in relation to Politically Exposed Persons (PEPs), enhanced due diligence (EDD)
measures must be applied on a risk sensitive basis.
Customer Screening:
When obtaining CDD or carrying on ongoing monitoring, the Company will perform searches
against its customer’s name, and against the names of the beneficial owners, controllers,
beneficiaries etc. These searches can be performed using a wide variety of risk management
systems or public domain searches.
When conducting searches against the name of an individual or entity, the Company shallconsider “negative press” in addition to whether the individual or entity is named on a
sanctions or PEP list. Negative press is the term given to any negative information, whether
alleged or factual. This could be anything from an allegation of fraud by a disgruntled former
customer to an article in a newspaper relating to a criminal investigation. Consideration will begiven to the credibility of the information source, the severity of the negative press, how recent
the information is and the potential impact the negative press would have on the business
relationship with that customer.
The Company will document:▪ the source and date of the search;▪ actions taken to confirm or discount any potential match;▪ details of the negative press;▪ any actions taken to verify or disprove the claims; and▪ any additional actions taken as a result of this information such as treating the customer ashigh risk and/or seeking proof of source of wealth/funds etc.
Simplified Due Diligence:
In general, the full range of CDD measures shall be applied by the Company. However,
Simplified Due Diligence measures (“SDD”) shall be implemented in cases where lower risks
have been identified and where the CDD measures are commensurate with the lower risk
factors. The following are examples of possible SDD measures that the Company may apply:▪ verifying the identity of the customer and beneficial owner after the establishment of thebusiness relationship;▪ reducing the degree of ongoing monitoring and transaction monitoring, based on areasonable monetary threshold in accordance with the customer’s profile;

Axiory Global Ltd. is licensed and regulated by the FSC Belize Registration No. 000122/08.

6▪ relying on a third party to conduct verification of identity of the customer.
The possibility of applying SDD measures does not remove from the Company its responsibility
to adopt CDD measures, it only allows for application of reduced measures. There may beinstances, depending on the level of risk and all the known circumstances (a high-risk
relationship e.g., PEPs will be dealt with more caution rather than the routine CDD measures),where it is inappropriate to adopt these SDD measures.
Under all circumstances, the Company must keep the customer risk assessment up to date andreview the appropriateness of CDD obtained even if SDD measures are adopted. The Company
shall keep the risk assessment and level of CDD requirements under review and the level ofrisk of the CDD measures should be consistent with the risk of the relationship.
The Company may apply SDD measures where lower risks have been identified and the SDD
measures shall be commensurate with the lower risk factors. Where the Company decides toadopt the SDD measures in respect of a particular applicant, it must:(a) document that decision in a manner which explains the factors which it took into account(including retaining any relevant supporting documentation) and its reasons for adopting
the measures in question; and(b) keep the relationship with the applicant (including the continued appropriateness of using
the SDD measures) under review, and operate appropriate policies, procedures andcontrols for doing so.
SDD shall never apply where the Company knows, suspects, or has reasonable grounds forknowing or suspecting that a customer or an applicant for business is engaged in money
laundering or terrorism financing or that the transaction being conducted by the customer orapplicant for business is being carried out on behalf of another person engaged in money
laundering or where there are other indicators of ML-TF risk. Where SDD measures are
adopted, the Company shall apply a risk-based approach to determine whether to adopt the
SDD measures in a given situation and/or continue with the SDD measures, although thesecustomers’ accounts are still subject to transaction monitoring obligations.
Enhanced Due Diligence:
The Company shall implement internal controls and other procedures to combat money
laundering and financing of terrorism, including Enhanced Due Diligence (“EDD”) procedureswith respect to high-risk persons, business relations and transactions and persons establishedin jurisdictions that do not have adequate systems in place to combat money laundering andfinancing of terrorism.
Where the ML-TF risks are identified to be higher, the Company shall take EDD measures tomitigate and manage those risks. The Company must assign a high-risk rating to the applicant
for business where a high risk of ML-TF has been identified. The EDD measures that may apply
for higher risk relationships should include:(a) requesting additional information on the customer and updating on a frequent basis thecustomer or the beneficial owner;

Axiory Global Ltd. is licensed and regulated by the FSC Belize Registration No. 000122/08.

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(b) obtaining additional information on the intended nature of the business relationship andthe source of funds/wealth;(c) obtaining information on the intended or performed transactions;(d) obtaining the approval of senior management to commence or continue the business
relationship;(e) conducting close monitoring of the business relationship;(f) any other measures the Company may undertake with relation to a high-risk relationship.
In case where the Company is unable to perform the required EDD requirements, it shall notcommence or it shall terminate the business relationship and consider filing a suspicioustransaction report.
Suspicious Activity Reporting:
Where a transaction is inconsistent in amount, origin, destination, or type with a customer’s
known, legitimate business or personal activities, the transaction shall be consideredsuspicious. Complex transactions or structures may have entirely legitimate purposes,
however, the Company shall pay attention to all complex, unusual, large transactions, and all
unusual patters of transactions, which have no apparent economic or visible lawful purpose.
An unwillingness on behalf of a customer to provide the requested information is also grounds
for suspicion.
All employees, regardless of whether they have a compliance function, are obliged to reportto the Company’s Anti-Money Laundering Compliance Officer (“AMLCO”) each instance inwhich they have knowledge, suspicion or reasonable grounds for suspicion that funds or assets
are criminal property or that a person in involved in ML-TF.
On receipt of a report concerning suspicious activity or customer, the AMLCO shall determine
whether the information contained in such report supports the suspicion. The AMLCO shallinvestigate the details in order to determine whether in all the circumstances he in turn should
submit a Suspicious Transaction Report (“STR”) to the Belize Financial Intelligence Unit (“FIU”).
If the AMLCO decides that the information does not substantiate a suspicion, he would
nevertheless be required to record fully the reasons for his decision not to report to the FIU.
Reporting STRs will allow the FIU to build a clearer picture of the ML-TF threat to Belize, andto use such intelligence on a proactive basis.
VI. ONGOING MONITORINGThe Company must monitor its business relationships on an ongoing basis, which includes:▪

▪
▪

scrutiny of transactions undertaken throughout the course of the relationship (including,where necessary, the source of funds) to ensure that the transactions are consistent with
the Company’s knowledge of the customer, his business and risk profile;
determining whether the customer is a PEP;
determining whether a customer relationship involves a country or territory that
represents a higher risk for ML-TF, corruption, or being subject to international sanctions,
including but not limited to, a country that has been identified by the FATF or CFATF(Caribbean Financial Action Task Force) as being higher risk;

Axiory Global Ltd. is licensed and regulated by the FSC Belize Registration No. 000122/08.

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▪
▪

adjusting risk profiles and risk assessments based on information reviewed; andensuring that the documents or information obtained for the purposes of applying CDD are
kept up-to-date.

Up-to-date Record Keeping:
Documents or information obtained for the purposes of applying CDD measures, held about
customers, must be kept up-to-date. Once the identity of a customer has been satisfactorily
verified, there is no obligation to re-verify identity (unless doubts arise as to the veracity or
adequacy of the evidence previously obtained for the purposes of customer identification) as
risk dictates however, the Company must take steps to ensure it holds appropriate up-to-date
information on its customers. A range of trigger events, such as an existing customer applying
to open a new account or establish a new relationship, might prompt the Company to seek
appropriate evidence.
VII. EMPLOYEE SCREENING

The Company shall implement programmes for screening procedures so that high standards
are maintained when hiring employees. Employee screening shall be conducted at the time ofrecruitment, periodically thereafter, and where a suspicion has arisen as to the conduct of theemployee.
Moreover, the Company shall ensure that its employees are competent and proper for thedischarge of the responsibilities allocated to them.
VIII. ANTI-MONEY LAUNDERING COMPLIANCE OFFICER

The Company has appointed an Anti-Money Laundering Compliance Officer (“AMLCO”), whose
principal functions are:(a) to oversee and monitor the Company’s compliance with the Belize AML-CFT laws,
regulations, codes or guidelines being in force;(b) receive and consider internal reports on unusual transactions and suspicious activities;(c) consider whether a STR should be made to the FIU; and(d) where he considers a STR should be made, submit the STR.
IX. INDEPENDENT AUDITThe Company ensures that its AML-CFT policies, procedures and controls are objectively
evaluated by a qualified and independent internal audit function. The main responsibilities of
the audit function are to:(a) assess the reliability, integrity and completeness of the Company’s AML-CFT policies,
procedures and controls;(b) evaluate the Company’s risk assessment processes and the risk ratings the Company has
assigned with respect to its customers, business relationships, countries or geographic
areas, services, delivery channels, products and transactions;(c) assess the adequacy, accuracy and completeness of employee training and awarenessprogrammes; andAxiory Global Ltd. is licensed and regulated by the FSC Belize Registration No. 000122/08.

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(d) review the Company’s past audit reports to assess the efficacy with which the Company
has implemented previously recommended changes.
The audit is documented and retain in accordance with the Company’s record keeping policies
and procedures, and the results are reported directly to senior management and theCompany’s Board of Directors for timely action.
X.

TRAINING

Programmes against money laundering and terrorism financing shall be in place to include
ongoing training programme for the directors, officers, employees and contractors of theCompany, to maintain awareness of the laws and regulations relating to money laundering andterrorism financing to:(a) assist them in recognising transactions and actions that may be linked to money
laundering or terrorism financing; and(b) instruct them in the procedures to be followed where any links have been identified underparagraph (a).
XI. REVIEW OF THIS POLICYThe Company shall monitor the effectiveness of this Policy as part of its compliance monitoring
programme. This Policy shall be reviewed periodically, and at least annually, to ensure it
continues to meet the Company’s compliance obligations and standards.
XII. APPROVAL OF THIS POLICYThe Company’s senior management and Board of Directors has approved this Policy in writing
as reasonably designed to achieve and monitor the Company’s ongoing compliance with therequirements of this Policy. Any significant changes to this Policy shall be pre-approved by theCompany’s senior management and Board of Directors.

Axiory Global Ltd. is licensed and regulated by the FSC Belize Registration No. 000122/08.

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