1. Introduction
SD Capital Pte Ltd, conducting business as TradeWithCapital, herein referred to as “The Company,” “We,” or “Our,” is steadfast in upholding the highest standards of anti-money laundering (“AML”) compliance. Our dedication encompasses strict adherence to all relevant global laws and regulations aimed at combating money laundering and terrorist financing. This Anti-Money Laundering Policy articulates the Company’s commitment to AML and counter-terrorist financing, encompassing the identification of beneficial owners, embargo policies, record-keeping, reporting of suspicious activities, and ongoing training. Additionally, it encompasses considerations regarding recent developments related to sanctioned countries.

2. Scope
This Policy applies to all employees, contractors, and third parties acting on behalf of SD Capital Pte Ltd. The standards outlined here are the minimum requirements based on applicable legal and regulatory requirements.

3. Objectives
The primary objectives of this Anti-Money Laundering (AML) Policy are multifaceted, encompassing a comprehensive approach to safeguard the integrity of the Company, its employees, and clients from being exploited for money laundering, terrorist financing, and other financial crimes. The key goals are as follows:

Prevention of Misuse:

Prevent the misuse of the Company, its resources, and the individuals associated with it as conduits for money laundering, terrorist financing, or any illicit financial activities.
Mitigate the risk of the Company inadvertently becoming a vehicle for criminal enterprises seeking to legitimize or conceal the origins of illicit funds.

Establishment of a Robust Framework:

Establish a robust and adaptable framework designed to combat money laundering and the financing of terrorism.
Implement systematic procedures, protocols, and controls to identify, assess, and manage the risks associated with money laundering and terrorist financing activities.

Ensure ongoing compliance with evolving legal and regulatory requirements to stay ahead of emerging threats and vulnerabilities in the financial landscape.

These objectives collectively underscore the Company’s commitment to maintaining the highest standards of financial integrity, fostering trust among stakeholders, and contributing to the broader global effort to combat financial crimes. The AML Policy serves as a proactive and dynamic tool to uphold ethical business practices, protect against illicit financial activities, and reinforce the Company’s dedication to regulatory compliance and social responsibility.

4. Applicability
The Monetary Authority of Singapore (MAS), in its Notice and Guidelines on Prevention of Money Laundering and Countering the Financing of Terrorism, requires the Company to apply the principles listed below.

1. Due Diligence when dealing with customers and their appointed representatives, connected parties and beneficial owners.
2. Compliance with laws such that the Company conducts business with high ethical standards and in compliance with laws and regulations.
3. Co-operation with law enforcement agencies to disclose suspicious transactions to the relevant law enforcement authorities in Singapore.
4. Policies, procedures and training ensure that necessary procedures for customer identification, retention of records, reporting of suspicious transactions and training of staff are in place, and that all policies, procedures and training of the staff are kept up to date.

As a matter of policy, the Company has adopted procedures its senior management and officers are required to comply with the following:
Exercising due diligence when undertaking providing services to clients.
Assisting and cooperating with the relevant law enforcement authorities in Singapore in preventing money laundering and terrorist financing.

5. Definition and Purpose
Money laundering (“ML”) is the process by which criminals seek to disguise the true origin and ownership of the proceeds of crime in order to make the funds appear to have originated from a legitimate source and facilitate their entrance into the lawful economy.

The financing of terrorism (“FT”) is the act of willingly providing, collecting or raising funds (whether directly or indirectly) with the intention that they should be used, or in the knowledge that they are likely to be used, in support of an act of terrorism. For the purposes of this policy, financing related to the proliferation of weapons of mass destruction, is encompassed within the definition of FT. The act of FT is often linked to ML activities. However, funds used for FT are not only obtained from criminal activity but legitimate means also, such as charitable donations or lawful business operations.

SD Capital Pte Ltd is committed to preventing ML/FT, and to maintaining compliance with all applicable anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) laws and regulations.

Purpose
This document sets out the Company’s policy on AML/CFT (the “Policy”). The purpose of the Policy is to establish standards for the Company’s AML/CFT compliance program. When formulating the Policy, the Company has taken into account the following legislation, guidance and notices:
(i) The Payment Services Act 2019 (No. 2 of 2019);
(ii) MASNoticePSN02–Prevention of Money Laundering and Countering the Financing of Terrorism – 5 December 2019 (the “Notice”);
(iii) Guidelines to MAS Notice PS-N02 on Prevention of Money Laundering and Countering the
Financing of Terrorism – 16 March 2020 (the “Guidelines”);
(iv) The Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (Cap. 65A) (“CDSA”);
(v) The Terrorism (Suppression of Financing) Act(Cap.325)(“TSOFA”); and
(vii) The MAS Act (Cap. 186) and regulations issued pursuant to section 27A thereto.

6. Business Process Control
KYC – Know Your Customer Procedures

As part of the Company’s AML Policy, we have established procedures to verify the identity of all clients before they receive payout commissions as contractors. Before opening a contractor account for an individual client, SD Capital Pte Ltd will conduct a KYC (Know Your Customer) process, and require satisfactory documentary evidence of the client’s:

– Name
– Address
– Date of birth
– Passport or National ID
– Proof of address
– Any other documentation required by local authorities

Name Screening and Monitoring

SD Capital Pte Ltd will not open accounts, accept funds, or securities from individuals, entities, or high-risk clients (in terms of money laundering or terrorist financing) without conducting enhanced due diligence. We will conduct well-documented due diligence regarding these prospective clients.

The Compliance Team shall document minimum standards regarding the screening of clients, their appointed representatives, connected parties and beneficial owners against sanctions lists and PEP databases, ML/TF information sources, MAS Regulations issued pursuant to section 27A of the MAS Act and other lists issued by MAS and other relevant authorities from time to time, and in respect of adverse media. All screening results shall be recorded.

Name Screening shall take place:
(i) at on-boarding, prior to the effecting of any transaction or value transfer; (ii) when there are any changes or updates to

1) sanctions lists, MAS Regulations issued under section 27A of the MAS Act or other information provided to payment service providers by MAS or other relevant authorities; or

2) the natural persons appointed to act on behalf of the client or its connected parties or beneficial owners;

3) with respect to value transfer originators and beneficiaries, ahead of the execution of any value transfer request.

Adequate processes and systems will be implemented across the Company to ensure that name screening requirements are adhered to and where positive hits are identified, appropriate steps are taken in response.

Screening

The Company will also continuously monitor and adhere to the latest sanctions lists to ensure compliance with sanctions imposed by relevant authorities. Clients and transactions from sanctioned countries or individuals/entities listed on sanctions lists will be subjected to

stringent due diligence and may be declined if necessary, screening of the applicant names to the consolidated list published by the following data sources are monitored on a constant basis, includes but not limited to the following:

• Consolidated UN Sanctions List; • European Union Sanctions List; • UK HM Treasury List;
• OFAC Non-SDN Entity List;

• OFAC Sanctions List;
• OFAC’s Specially Designated Nationals & Blocked Persons; • Law enforcement (over 600 sources);
• Global Adverse media (over 10,000 sources);
• Global corporate registry data;
• MAS Control List

The continuous efficacy of this Anti-Money Laundering (AML) Policy is paramount to the Company’s commitment to regulatory adherence, industry standards, and the dynamic nature of AML and sanctions compliance. To ensure its relevance and effectiveness, the following principles are emphasized:

7. Regular Review and Updates:

This AML Policy will undergo regular reviews and updates, aligning with changes in regulatory requirements, emerging industry best practices, and the evolving landscape of AML and sanctions compliance. The Company is dedicated to staying abreast of evolving financial regulations, adapting to new challenges, and enhancing the AML framework to address emerging threats.
Collective Responsibility:

All employees and relevant stakeholders bear the shared responsibility of upholding and implementing this Policy effectively. By fostering a culture of collective vigilance, the Company aims to engage every individual in the commitment to AML compliance, promoting a robust defense against potential risks.

Compliance with AML Laws:

All personnel are obligated to comply with AML laws and regulations applicable to the Company’s operations. Regular training programs and awareness initiatives will be conducted to ensure that employees remain informed about AML laws and their implications.

Consequences of Non-Compliance:

Failure to adhere to the stipulations outlined in this AML Policy may result in disciplinary action against employees. Legal consequences may be pursued against those found in breach of AML laws and internal policies.

The Company reserves the right to terminate relationships with clients or entities that fail to comply with AML requirements, safeguarding the integrity of its operations and relationships. By reinforcing a culture of adaptability, continuous improvement, and collective responsibility, the Company aims to fortify its AML framework against evolving threats and to uphold the highest standards of integrity in financial operations.