Anti Money-Laundering Policy

1. Policy Statement
Alden Graff Capital maintains a zero-tolerance policy toward money laundering and is fully committed to:
• Preventing the use of our services for illicit purposes
• Complying with applicable AML laws and regulatory frameworks
• Ensuring appropriate client due diligence (CDD) and know-your-customer (KYC) measures
• Reporting suspicious activity to relevant authorities, as required

2. Legal and Regulatory Framework
We comply with the AML obligations established by:
• The Financial Action Task Force (FATF) Recommendations
• Local regulatory authorities in the jurisdictions where we operate
• Applicable sanctions and watchlists, including OFAC and UN lists

3. Customer Due Diligence (CDD)
Before establishing a business relationship, we carry out CDD procedures to verify the identity of clients and beneficial owners. These steps may include:
• Collection of valid government-issued identification
• Proof of address
• Verification of the source of funds
• Understanding the nature and purpose of the business relationship
Enhanced Due Diligence (EDD) may be applied in higher-risk scenarios, including but not limited to:
• Politically exposed persons (PEPs)
• Clients from high-risk jurisdictions
• Complex ownership structures or unusual transaction patterns

4. Ongoing Monitoring
We continuously monitor client activity to identify and assess unusual or suspicious behavior. This includes:
• Reviewing transaction patterns for consistency with the client’s profile
• Updating client information periodically
• Conducting risk assessments for existing and new clients
If suspicious activity is detected, a report will be filed with the relevant Financial Intelligence Unit (FIU) in accordance with legal obligations.

5. Record Keeping
In compliance with AML regulations, Alden Graff Capital maintains:
• Client identity records
• Transaction histories
• Suspicious activity reports (SARs)
• Documentation of due diligence and risk assessments
These records are retained for a minimum of five (5) years or longer, depending on jurisdictional requirements.

6. Staff Training
We provide ongoing AML training to all relevant employees to ensure they:
• Understand AML laws and internal procedures
• Recognize signs of suspicious activity
• Know how to escalate concerns and report internally
Training is updated regularly to reflect changes in law and emerging typologies.

7. Internal Controls and Compliance Oversight
Our AML compliance program is overseen by a designated Compliance Officer, who is responsible for:
• Implementing AML policies and procedures
• Monitoring compliance and effectiveness
• Filing SARs and coordinating with law enforcement when necessary
• Reporting to senior management and/or the board
Regular audits are conducted to assess the adequacy of internal controls and adherence to AML requirements.

8. Reporting Suspicious Activity
All employees are required to report suspected money laundering or suspicious activity immediately to the Compliance Officer. Failure to report may result in disciplinary action and potential legal consequences.
We cooperate fully with law enforcement agencies and regulatory authorities as required by law.

9. Sanctions Compliance
We screen all clients and transactions against global sanctions lists, including:
• U.S. Office of Foreign Assets Control (OFAC)
• European Union Sanctions List
• United Nations Security Council Consolidated List
No business will be conducted with individuals or entities identified on these lists, or in jurisdictions subject to comprehensive sanctions.

10. Policy Review
This AML Policy is reviewed and updated on an annual basis or as required by changes in applicable laws or regulations.

Contact Information
For questions or concerns regarding this AML Policy, please contact:

Compliance Department
Alden Graff Capital
[Insert Office Address]
Email: info@aldengraff.com
Phone: [Insert Phone Number]