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Anti-Money Laundering (AML) Policy Aninda Solutions Ltd.

Introduction Aninda Solutions Ltd. is fully committed to combating money laundering (ML) and terrorist financing (TF) and has implemented this comprehensive Anti-Money Laundering Policy (hereinafter, "Policy") to ensure compliance with all applicable laws, regulations, and directives. This Policy is designed to align with the highest international standards, including those set forth by the Financial Action Task Force (FATF), the Anjouan Offshore Financial Authority, and other relevant jurisdictions in which Aninda Solutions Ltd. operates. The key objective of this Policy is to prevent the company from being exploited for the purposes of ML, TF, or any other criminal activity. This Policy outlines the principles and procedures that are followed to detect, prevent, and report potential instances of ML and TF, in compliance with the legal and regulatory framework that governs such activities.
Scope of Application This Policy applies to all employees, directors, officers, agents, consultants, and any third parties acting on behalf of Aninda Solutions Ltd. (hereinafter, "Personnel"). It also applies to all customers and counterparties engaging in business with Aninda Solutions Ltd. The provisions of this Policy establish the minimum standards required for anti-money laundering compliance, and failure to adhere to this Policy may result in disciplinary action, including but not limited to termination of employment or contractual arrangements, as well as possible legal consequences.
Legal Framework and Compliance Aninda Solutions Ltd. adheres to all relevant national and international anti-money laundering laws and regulations, including but not limited to: The Financial Action Task Force (FATF) Recommendations. The Anjouan Offshore Financial Authority’s AML Regulations. Any applicable national and regional AML legislation. The company is also guided by the principles enshrined in global anti-money laundering frameworks, which include measures to prevent the illicit use of its financial system and ensure that its services are not used to launder funds or finance terrorism.
Roles and Responsibilities The responsibility for ensuring compliance with this AML Policy lies at all levels within Aninda Solutions Ltd. The following roles have specific responsibilities: 4.1 Board of Directors and Senior Management The Board of Directors is responsible for overseeing the implementation of the AML Policy and ensuring that sufficient resources are allocated to compliance efforts. Senior Management is tasked with ensuring that effective AML controls are in place and regularly reviewed to address emerging risks. 4.2 Anti-Money Laundering Compliance Officer (AMLCO) The AMLCO is responsible for overseeing all aspects of the company's AML program. This includes the development and implementation of AML procedures, the monitoring of transactions, the reporting of suspicious activities, and the provision of ongoing training for Personnel. The AMLCO also acts as the liaison between Aninda Solutions Ltd. and relevant regulatory authorities.
Know Your Customer (KYC) Procedures Aninda Solutions Ltd. employs a risk-based approach to customer due diligence (CDD) as part of its Know Your Customer (KYC) process. The KYC process involves verifying the identity of customers and ensuring that they do not pose an undue risk for involvement in ML or TF activities. The KYC process includes the following steps: 5.1 Customer Identification Customers must provide accurate and up-to-date identification documents, including but not limited to: Government-issued identification (passport, national ID card, driver’s license). Proof of address (utility bills, bank statements, or other documents showing a residential address). 5.2 Enhanced Due Diligence (EDD) For high-risk customers or transactions, Enhanced Due Diligence (EDD) is required. EDD may include obtaining additional information on the customer’s source of funds, source of wealth, and purpose of the transaction. This applies particularly to customers or transactions from jurisdictions known for higher risks of ML and TF, or where red flags have been identified in the customer’s transaction patterns.
Transaction Monitoring Aninda Solutions Ltd. is committed to continuously monitoring transactions conducted by its customers to identify and report any suspicious activity. The monitoring system will include automated systems capable of flagging unusual or large transactions that deviate from the customer’s normal behavior or profile. 6.1 Ongoing Monitoring All customer accounts and transactions are subject to ongoing monitoring, ensuring that any changes in behavior or unusual patterns are detected promptly. Any transaction exceeding EUR 10,000, or any suspicious transaction, will be subject to additional scrutiny and may require further investigation. 6.2 Red Flags Examples of activities that may raise suspicion include, but are not limited to: Large or frequent deposits that do not match the customer's known income or transaction profile. Transactions involving high-risk jurisdictions or financial secrecy havens. Unusually structured transactions designed to avoid reporting thresholds. Personnel who become aware of any unusual or suspicious activity are required to immediately report such activity to the AMLCO for further investigation.
Reporting Suspicious Transactions If any activity or transaction appears suspicious, Aninda Solutions Ltd. will promptly file a Suspicious Activity Report (SAR) with the relevant authorities, as required by applicable law. The decision to file a SAR will be made by the AMLCO after reviewing all available information. 7.1 Internal Reporting All employees are obligated to report any suspicious activity to the AMLCO without delay. Failure to report suspicious activity may result in disciplinary action. Employees will not face any adverse consequences for reporting suspicious activities in good faith, even if the report does not result in further action. 7.2 External Reporting The AMLCO is responsible for filing SARs with the Financial Intelligence Unit (FIU) or other competent authorities in accordance with regulatory requirements. Once a SAR has been filed, the AMLCO will continue to monitor the relevant account(s) for further suspicious activity.
Record-Keeping Aninda Solutions Ltd. maintains detailed records of all transactions and KYC information for a minimum period of five (5) years, or as required by applicable law. This includes but is not limited to: Customer identification documents. Transaction history. Communications and reports related to suspicious activities. All records will be securely stored, and access will be limited to authorized Personnel only.
Risk-Based Approach The company adopts a risk-based approach to AML compliance, ensuring that the level of due diligence and monitoring is proportionate to the risks associated with specific customers, transactions, or jurisdictions. 9.1 Low-Risk Customers For low-risk customers, simplified due diligence (SDD) measures may be applied. This typically involves collecting basic identification information and conducting standard transaction monitoring. 9.2 High-Risk Customers For high-risk customers or transactions, additional measures are required, including enhanced due diligence (EDD). This includes a more thorough examination of the customer's financial background, the source of funds, and transaction history. Aninda Solutions Ltd. regularly reviews its risk management policies to ensure that they remain effective in identifying and mitigating risks.
Staff Training and Awareness To ensure that all Personnel are adequately prepared to comply with the AML Policy, Aninda Solutions Ltd. implements ongoing AML training programs. These training programs are mandatory for all employees, including new hires, and will cover: The legal obligations related to AML/TF compliance. The identification of suspicious activities and red flags. Internal reporting procedures and the role of the AMLCO. Training will be updated regularly to reflect changes in AML regulations and industry best practices.
Data Protection and Confidentiality Aninda Solutions Ltd. is committed to protecting the personal data of its customers in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR) and other relevant laws. All personal data collected for AML purposes will be stored securely and will not be shared with third parties unless required by law or regulation. The company ensures that all SARs, customer information, and transaction records are treated as confidential and shared only with authorized Personnel and regulatory authorities as required.
Review and Update of Policy This AML Policy will be reviewed and updated on an annual basis or as required to reflect changes in legal requirements, regulatory expectations, or business operations. Any material changes to this Policy must be approved by Senior Management and the Board of Directors.
Conclusion Aninda Solutions Ltd. is dedicated to ensuring full compliance with all applicable anti-money laundering and counter-terrorist financing laws. The company's commitment to this Policy reflects its broader dedication to upholding the integrity of its business practices and protecting its customers from any risks associated with financial crime.

This Policy is effective as of 10/10/2024 and remains in force until further notice.