Anti-Money Laundering & Know Your Customer Policy

1. Policy Statement

Moris Nou Pei is committed to the highest standards of Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Counter-Proliferation Financing (CPF) compliance. We will not knowingly facilitate, be used as a channel for, or turn a blind eye to:

• Money laundering — the concealment, conversion, or transfer of proceeds of crime;
• Terrorist financing — providing funds, directly or indirectly, to terrorist individuals or organisations;
• Tax evasion or any other financial crime;
• Corruption or bribery as defined under the Prevention of Corruption Act 2002.

2. Know Your Customer (KYC) Requirements

2.1 Identity Verification

Before transacting on the Platform — including unlocking opportunity details, reporting deal closures, or posting investment mandates — users may be required to provide:

2.2 Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied to:

• Politically Exposed Persons (PEPs) — current or former holders of public office, their family members and close associates;
• Transactions above USD 50,000 equivalent;
• Users from or transacting with FATF high-risk jurisdictions;
• Transactions flagged by our automated risk-scoring system.

EDD may include additional document requests, source of wealth verification, video verification, or senior management approval before proceeding.

2.3 Ongoing Monitoring

We continuously monitor transactions and user behaviour for unusual patterns, including but not limited to: sudden large transactions, frequent changes to account details, transactions inconsistent with stated business purpose, and structuring (splitting transactions to avoid thresholds).

3. Risk-Based Approach

Moris Nou Pei classifies users and transactions by risk level:

4. Sanctions Screening

All users are screened against:

• United Nations Security Council (UNSC) sanctions lists;
• OFAC (US Treasury) Specially Designated Nationals list;
• EU Consolidated Financial Sanctions List;
• UK HM Treasury sanctions list;
• Mauritius domestic sanctions issued by the Prime Minister's Office.

Any match or positive hit will result in immediate account suspension and mandatory reporting to the FIU of Mauritius under Section 14 of FIAMLA 2002.

5. Suspicious Transaction Reporting

Where Moris Nou Pei has reasonable grounds to suspect that a transaction involves proceeds of crime, terrorist financing, or any other predicate offence, we are legally obliged under Section 14 of FIAMLA 2002 to file a Suspicious Transaction Report (STR) with the Financial Intelligence Unit (FIU) of Mauritius.

6. User Obligations Under This Policy

By using Moris Nou Pei, you represent, warrant, and covenant that:

1. All funds invested or received through the Platform are from legitimate, lawfully-obtained sources;
2. You are not subject to any economic, trade, or financial sanctions;
3. You are not a beneficial owner of, or acting on behalf of, any sanctioned entity or individual;
4. You will promptly provide any KYC documentation requested by Moris Nou Pei within 5 business days;
5. You will notify Moris Nou Pei immediately if any of the above representations become untrue.

Failure to comply with KYC requests will result in suspension of account access until compliance is achieved. Where compliance is refused or documents are found to be fraudulent, the account will be permanently closed and the matter reported to the FIU.

7. Record Keeping

In accordance with Regulation 5 of the FIAMLA Regulations 2018, Moris Nou Pei retains:

• KYC documentation for a minimum of 7 years from the end of the business relationship;
• Transaction records for a minimum of 7 years from the date of each transaction;
• STR records for a minimum of 7 years.

8. Training & Governance

Moris Nou Pei appoints a designated Money Laundering Reporting Officer (MLRO) responsible for:

• Receiving internal suspicious activity reports;
• Determining whether STRs are required;
• Liaising with the FIU of Mauritius;
• Ensuring staff receive adequate AML/CTF training.

Contact the MLRO at: compliance@morisnoupei.com