Anti-Money Laundering (AML) Policy

Berdain LLP ("Berdain LLP," "we," "us," or "our") is fully committed to preventing money laundering and terrorist financing activities. This Anti-Money Laundering (AML) Policy outlines our procedures and controls designed to detect, prevent, and report suspicious activities in compliance with applicable laws and regulations, including those related to Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF).

1. Introduction and Purpose

Money laundering (ML) is the process of concealing the origins of illegally obtained money, typically by means of transfers involving foreign banks or legitimate businesses. Terrorist financing (TF) involves providing or collecting funds, by any means, directly or indirectly, with the intention that they be used, or in the knowledge that they are to be used, in full or in part, to carry out terrorist acts.

Berdain LLP recognizes the critical importance of combating financial crime to protect the integrity of the global financial system and to prevent our services from being used for illicit purposes. This policy establishes the framework for our AML/CTF compliance program.

2. Scope of the Policy

This policy applies to all partners, employees, agents, and services offered by Berdain LLP, including but not limited to:

• Company Formation
• Merchant Account Setup
• Nominee Director Services
• Offshore Banking Assistance
• Accounting & Reporting
• Corporate Secretary Services
• Virtual Office
• Gaming License Assistance

3. Key Pillars of Our AML/CTF Program

Our AML/CTF program is built upon the following fundamental pillars:

3.1. Risk-Based Approach

We adopt a risk-based approach to identify, assess, and understand the money laundering and terrorist financing risks to which Berdain LLP is exposed. This allows us to apply resources more effectively by focusing on areas of higher risk. Our risk assessment considers:

• Client Risk: Type of client (individual, corporate, trust), geographic location, occupation/industry, and reputation.
• Service Risk: The nature of the services requested (e.g., company formation, banking, nominee services).
• Geographic Risk: Countries or jurisdictions involved in the transaction or the client's operations.
• Delivery Channel Risk: How services are delivered and transactions are conducted.

3.2. Customer Due Diligence (CDD) and Know Your Customer (KYC)

A robust CDD/KYC process is central to our AML/CTF efforts. We collect and verify identification information for all clients and, where applicable, their beneficial owners and controlling persons. This includes:

• Identity Verification: Obtaining and verifying official identification documents (e.g., passports, national ID cards) for individuals.
• Address Verification: Obtaining and verifying proof of residential or business address (e.g., utility bills, bank statements).
• Beneficial Ownership Identification: Identifying and verifying the identity of all ultimate beneficial owners (UBOs) of corporate entities, trusts, or other legal arrangements.
• Purpose and Nature of Business: Understanding the purpose and intended nature of the business relationship, including the source of funds and source of wealth.
• Politically Exposed Persons (PEPs) and Sanctions Screening: Screening clients and their beneficial owners against international sanctions lists (e.g., OFAC, UN, EU) and databases of Politically Exposed Persons (PEPs).

3.3. Enhanced Due Diligence (EDD)

For clients identified as high-risk (e.g., those from high-risk jurisdictions, PEPs, complex structures, or engaging in high-value transactions), we apply Enhanced Due Diligence (EDD) measures. EDD involves:

• Gathering additional information on the client, beneficial owners, and source of funds/wealth.
• Obtaining senior management approval for establishing or continuing the business relationship.
• Conducting more frequent and rigorous ongoing monitoring.

3.4. Ongoing Monitoring

We conduct ongoing monitoring of client relationships and transactions to ensure that activities are consistent with our knowledge of the client, their business, and risk profile. This includes:

• Regular review and updating of client due diligence information.
• Monitoring transactions for unusual patterns or deviations from expected activity.
• Reviewing news and public information for any adverse media concerning clients.

3.5. Suspicious Activity Reporting (SAR)

All partners and employees are trained to recognize and report suspicious activities. If any activity or transaction raises suspicion of money laundering or terrorist financing, an internal report will be made to the designated Money Laundering Reporting Officer (MLRO).

• MLRO Appointment: Berdain LLP has appointed a Money Laundering Reporting Officer (MLRO) responsible for overseeing the AML/CTF program, receiving internal suspicious activity reports, and making external reports to the relevant financial intelligence unit (FIU) or law enforcement authorities.
• No Tipping-Off: Employees are strictly prohibited from "tipping off" or informing a client or any third party that a suspicious activity report has been filed or that an investigation is underway.

3.6. Record Keeping

We maintain comprehensive records of all client identification documents, due diligence information, transaction data, and suspicious activity reports for a period of at least five to seven years after the termination of the business relationship, or as required by applicable laws and regulations.

3.7. Internal Controls and Training

• Internal Controls: We implement robust internal controls, policies, and procedures to ensure compliance with AML/CTF regulations. These controls are regularly reviewed and updated.
• Employee Training: All relevant employees receive mandatory AML/CTF training upon joining Berdain LLP and annually thereafter. Training covers the latest regulations, money laundering typologies, red flags, and reporting procedures.

4. Compliance Officer

The MLRO is responsible for the overall implementation and oversight of Berdain LLP's AML/CTF compliance program.

5. Consequences of Non-Compliance

Berdain LLP reserves the right to:

• Refuse to establish a business relationship with any individual or entity.
• Terminate an existing business relationship.
• Delay or block transactions.
• Report suspicious activities to the relevant authorities.

Any failure by a client to provide required information or any engagement in suspicious activities will lead to immediate review and potential termination of services, without refund of fees paid.

6. Changes to This Policy

Berdain LLP reserves the right to modify or update this AML Policy at any time to reflect changes in laws, regulations, or best practices. Any changes will be effective immediately upon posting on our website. We encourage you to review this policy periodically.

7. Contact Us

If you have any questions about this AML Policy, please contact us at: