1. Purpose

The purpose of this AML and CTF Policy is to establish guidelines and procedures for preventing and detecting money laundering and the financing of terrorism. UNIQFINANCIAL S.A. is committed to complying with all applicable laws and regulations, including those of the Dominican Republic and relevant international standards.

2. Scope

This policy applies to all employees, officers, directors, contractors, and agents of UNIQFINANCIAL S.A. It covers all activities conducted by the company, including client interactions, transactions, and reporting obligations.

3. Definitions

• Money Laundering: The process of disguising the origins of illegally obtained money so that it appears legitimate.
• Terrorism Financing: The provision of funds or financial services to support terrorist activities.
• Suspicious Activity: Any transaction or behavior that raises suspicion of money laundering or terrorism financing.

4. Responsibilities

• Compliance Officer: The Compliance Officer is responsible for implementing and overseeing the AML and CTF programs, including training, monitoring, and reporting. The Compliance Officer serves as the primary point of contact with regulatory authorities.
• Employees and Contractors: All employees and contractors are required to adhere to this policy and report any suspicious activities to the Compliance Officer.

5. Customer Due Diligence (CDD)

• Identification and Verification: Before establishing a business relationship, UNIQFINANCIAL S.A. must identify and verify the identity of all clients. This includes obtaining and verifying personal information (e.g., name, address, date of birth) and corporate information (e.g., company name, registration number).
• Enhanced Due Diligence (EDD): For clients identified as higher risk (e.g., politically exposed persons, clients from high-risk jurisdictions), additional measures must be taken, such as obtaining more detailed information and conducting more frequent monitoring.
• Ongoing Monitoring: All client relationships must be continuously monitored for unusual or suspicious activities. Transaction patterns should be analyzed to identify any deviations from normal behavior.

6. Risk Assessment

• Risk-Based Approach: UNIQFINANCIAL S.A. adopts a risk-based approach to AML and CTF, prioritizing resources and controls based on the level of risk posed by clients, transactions, and geographic regions.
• Risk Factors: Factors to consider include the nature of the client's business, transaction types, and the jurisdiction in which the client operates.

7. Record Keeping

• Document Retention: All records related to client identification, due diligence, and transactions must be maintained for a minimum of five years after the business relationship ends. This includes copies of identification documents, transaction records, and reports of suspicious activity.
• Accessibility: Records must be stored securely and be readily accessible to the Compliance Officer and regulatory authorities.

8. Reporting of Suspicious Activity

• Internal Reporting: Employees must report any suspicious activities or transactions to the Compliance Officer immediately. The report should include details of the transaction, the parties involved, and the reasons for suspicion.
• External Reporting: The Compliance Officer is responsible for filing Suspicious Activity Reports (SARs) with the appropriate authorities in accordance with local laws and regulations. Reporting must be done promptly and in strict confidence.

9. Training and Awareness

• Employee Training: All employees, especially those involved in client onboarding, transactions, and compliance, must undergo regular training on AML and CTF regulations, recognizing suspicious activities, and the procedures for reporting them.
• Ongoing Education: Training programs should be updated regularly to reflect changes in laws, regulations, and industry best practices.

10. Independent Audit

• Regular Audits: UNIQFINANCIAL S.A. will conduct regular independent audits of its AML and CTF programs to ensure compliance with legal requirements and the effectiveness of its controls.
• Audit Scope: The audit should include a review of client files, transaction records, the effectiveness of the CDD process, and the adequacy of reporting mechanisms.

11. Compliance with Laws and Regulations

• Regulatory Compliance: UNIQFINANCIAL S.A. is committed to complying with all applicable AML and CTF laws and regulations in the jurisdictions in which it operates, including those specific to the Dominican Republic.
• International Standards: The company also adheres to relevant international standards, such as the recommendations of the Financial Action Task Force (FATF).

12. Violations and Penalties

• Disciplinary Action: Any employee found to be in violation of this policy may face disciplinary action, up to and including termination of employment. Contractors and agents may have their contracts terminated.
• Legal Penalties: Violations of AML and CTF regulations can result in significant legal penalties, including fines and imprisonment. UNIQFINANCIAL S.A. will cooperate fully with law enforcement in the event of any legal proceedings.

13. Review and Updates

• Policy Review: This policy will be reviewed and updated annually or more frequently if required by changes in law, regulation, or the company’s operational environment.

• Approval: All updates to this policy must be approved by the Board of Directors of UNIQFINANCIAL S.A..