Anti-Money Laundering Policy

Introduction

Guardeer Funding (referred to as “the Company,” “we,” or “our”) is steadfast in maintaining the utmost standards in anti-money laundering (AML) compliance. We are committed to fulfilling our legal and regulatory obligations worldwide to prevent money laundering and terrorist financing. This Anti-Money Laundering Policy describes our duties concerning AML and counter-terrorist financing efforts. These include verifying the identity of beneficial owners, implementing embargo policies, maintaining accurate records, detecting and reporting suspicious activities, and conducting relevant training. Additionally, this policy covers updates concerning countries under sanctions.

Scope

This Policy is enforceable for all employees, contractors, and external entities working on behalf of Guardeer Funding. It establishes the foundational standards, derived from the pertinent legal and regulatory frameworks, that must be universally adhered to.

Objectives

The Anti-Money Laundering (AML) Policy of Guardeer Funding aims to:

• Safeguard the Company, including its workforce and clients, against exploitation for money laundering, terrorist funding, or any other illicit financial activities.
• Create a structured approach to prevent and counteract money laundering and the financing of terrorism.

Applicability

Under the Anti-Money Laundering Act of 2006, Guardeer Funding bears the responsibility of ensuring compliance by its subordinate entities, branches, subsidiaries, and international affiliates elsewhere. Where local regulations demand a higher standard than this Policy, such stringent requirements take precedence. Should discrepancies arise between this Policy and local laws, the affected entity of Guardeer Funding must seek guidance from the local legal team to rectify the issue. In situations where local constraints prevent the enactment of this Policy’s minimum standards, the Company will abstain from initiating, maintaining, or executing any business engagements. In jurisdictions where this Policy’s stipulations are unenforceable, existing business relationships must be concluded, overriding any other contractual or legal considerations.

Definition of Money Laundering

Money laundering is the act of engaging in financial transactions to conceal or alter the origin or character of money gained from illegal activities, like fraud, corruption, organized crime, or terrorism. The specific crimes constituting money laundering are identified by local legislation. Generally, the money laundering cycle includes these phases:

1. Placement: Introducing illegally obtained funds into the financial or non-financial system. b. Layering: Conducting complex transactions to dissociate criminal proceeds from their origins, thereby obfuscating the funds’ source. c. Integration: Reinjecting the cleansed money into the economy, presenting it as lawful assets.

These phases can intertwine and occur simultaneously, posing risks at various points in the financial sector.

Procedure Manual

Client Identification Procedures

Under our AML Policy, Guardeer Funding has developed identification protocols to authenticate all clients prior to disbursing contractor payouts. Initial setup of a contractor account involves a comprehensive KYC (Know Your Customer) assessment, mandating verifiable evidence of the client’s:

• Name
• Address
• Date of birth
• Passport or National ID
• Proof of address
• Additional documentation as mandated by local taxation laws

Sanctioned Countries and Prohibited Clients

Guardeer Funding is committed to stringent scrutiny and will not engage with individuals, corporations, or high-risk parties in money laundering or terrorism financing without extensive due diligence. This commitment extends to ongoing monitoring against updated sanctions lists to ensure adherence to the impositions by the governing bodies. Business with clients or involving countries or persons on these sanctions lists will undergo rigorous due diligence and may be rejected when deemed necessary.

The list of sanctioned countries currently includes: Afghanistan, Burundi, Central African Republic, Congo Republic, Cuba, Crimea, Democratic Republic of Congo, Eritrea, Guinea, Guinea-Bissau, Iran, Iraq, Laos, Liberia, Libya, Myanmar, North Korea, Papua New Guinea, Somalia, South Sudan, Sudan, Syria, Vanuatu, Venezuela, Yemen, and Zimbabwe.

We regularly review and refresh our AML Policy to stay aligned with new regulatory requirements, industry best practices, and the dynamic environment of AML and sanctions compliance. It is the collective responsibility of all employees and associated parties to abide by this Policy and the relevant AML regulations. Non-compliance may lead to disciplinary measures, legal repercussions, or severance of ties with entities failing to meet these standards.