AML/CFT/CPF Policy Statement

Monolith Market is the trading platform operated by Monolith Private Wealth Limited, which is the contractual counterparty for all services provided through Monolith Market. The FSC licences and the regulatory obligations described here are held by, and apply to, Monolith Private Wealth Limited.

1. Our Commitment

Monolith Private Wealth Limited (“MPW”, “we”, “us” or “our”) is committed to preventing the use of our services for money laundering (“ML”), the financing of terrorism (“TF”), the financing of the proliferation of weapons of mass destruction (“PF”), and any other form of financial crime.

As a company incorporated in the Republic of Mauritius and licensed by the Financial Services Commission (“FSC”) as an Investment Dealer and as an Investment Adviser, we are a reporting institution within the meaning of the Financial Intelligence and Anti-Money Laundering Act 2002 (“FIAMLA”). We take this responsibility seriously and apply a comprehensive, risk-based programme of policies, controls, and procedures designed to prevent and detect financial crime. This Policy Statement summarises our approach. It is intended to inform you, our current and prospective clients, of:

• The applicable legal and regulatory framework in Mauritius;
• The procedures we follow to know our clients and monitor their transactions;
• Our obligations regarding suspicious activity reporting;
• What we expect of our clients in supporting our compliance efforts; and
• Where you can find further information.

2. Regulatory Framework

Our AML/CFT/CPF programme is built on, and complies with, the following principal legal and regulatory instruments of the Republic of Mauritius:

• Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA) — The primary AML/CFT legislation in Mauritius, establishing the duty to conduct customer due diligence, maintain records, and report suspicious transactions to the Financial Intelligence Unit (FIU).
• Financial Intelligence and Anti-Money Laundering Regulations 2018 (FIAMLR) — Detailed rules on customer due diligence, enhanced due diligence, beneficial ownership identification, and risk-based procedures.
• Prevention of Terrorism Act 2002 (POTA) — Obligations relating to the identification, freezing, and reporting of assets linked to terrorism.
• United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Sanctions Act 2019 — Obligations relating to the implementation of United Nations sanctions and the screening of clients and counterparties against applicable sanctions lists.
• FSC AML/CFT Handbook — Sector-specific binding guidance issued by the FSC for licensees on AML/CFT compliance.
• Securities Act 2005 and Securities (Licensing) Rules 2007 — Foundational licensing framework and conduct obligations applicable to investment dealers and investment advisers.
• Financial Crimes Commission Act 2023 – Establishing the Financial Crimes Commission as the primary investigative and enforcement body relating to financial crimes in Mauritius.
• Anti-Money Laundering Act 2026 (AMLA 2026) – Latest addition to the AML/CFT Statutory environment in Mauritius, amending several key statutes to strengthen the AML/CFT requirements for Reporting Persons.

3. Key Concepts

3.1 Money Laundering

Money laundering is the process by which a person attempts to disguise the illegal origin of funds derived from criminal activity so that the funds appear to have a legitimate source. It typically involves three stages: (i) the placement of illicit funds into the financial system; (ii) the layering of transactions to obscure the trail; and (iii) the integration of the funds into the legitimate economy.

3.2 Terrorist Financing

Terrorist financing involves the collection, provision, or use of funds — whether of lawful or unlawful origin — with the intention that they should be used, or in the knowledge that they are to be used, to carry out acts of terrorism or to support terrorist organisations or individuals.

3.3 Proliferation Financing

Proliferation financing refers to the act of providing funds or financial services that are used, in whole or in part, for the manufacture, acquisition, possession, development, export, trans-shipment, brokering, transport, transfer, stockpiling or use of nuclear, chemical, or biological weapons and their means of delivery, including related materials.

3.4 Politically Exposed Person (PEP)

A Politically Exposed Person is an individual who is, or has been, entrusted with a prominent public function. This includes domestic PEPs, foreign PEPs, and PEPs of international organisations, together with their family members and close associates. PEPs are considered higher-risk clients in the AML/CFT framework and are subject to enhanced due diligence.

3.5 Beneficial Owner

A beneficial owner is the natural person who ultimately owns or controls a client, or the natural person on whose behalf a transaction or activity is being conducted. For corporate clients, this generally includes any natural person who directly or indirectly holds 25% or more of the entity's shares, voting rights, or economic interest, or who otherwise exercises control over the entity.

4. Our AML/CFT/CPF Programme

MPW maintains a comprehensive AML/CFT/CPF programme based on a risk-based approach, in line with s.17 of FIAMLA 2002, the Updated FSC AML/CFT Handbook and the FATF Recommendations. The depth and scope of the controls we apply to each client and transaction are calibrated to the assessed level of money laundering and terrorist financing risk.

4.1 Governance

The Board of Directors of MPW has ultimate accountability for the effectiveness of our AML/CFT/CPF programme. We have appointed a Money Laundering Reporting Officer (“MLRO”) who reports independently to the Board of Directors and is responsible for the day-to-day operation of the programme, including the review and submission of suspicious transaction reports. We have also appointed a Compliance Officer responsible for ensuring overall regulatory compliance.

4.2 Risk-Based Approach

We assess each client and each business relationship for money laundering and terrorist financing risk at onboarding and throughout the relationship. We assign each client a Money Laundering Risk Rating (“MLRR”) of Low, Medium, or High. The MLRR considers factors including (without limitation):

• The client's country of residence, nationality, and tax residence;
• The client's occupation, source of funds, and source of wealth;
• The client's expected trading activity and the products to be accessed;
• Whether the client is a PEP or has any connection to a PEP;
• Sanctions screening and adverse media findings; and
• The legal structure and ownership of corporate clients.

4.3 Customer Due Diligence (“CDD”)

We apply customer due diligence measures proportionate to the assessed risk:

4.4 Identification and Verification

We identify all our clients and, where applicable, the beneficial owners of corporate clients, before establishing a business relationship. We verify identity through independent and reliable sources including government-issued identity documents and electronic identity verification services. Our specific documentation requirements are set out in our KYC and Onboarding Requirements Notice.

4.5 Sanctions Screening

All clients, beneficial owners, directors, and authorised representatives are screened at onboarding and on an ongoing basis through a leading sanctions and PEP screening platform. We screen against the lists maintained by:

• The United Nations Security Council;
• The Republic of Mauritius under the UN Sanctions Act 2019;
• The European Union;
• The United Kingdom's Office of Financial Sanctions Implementation (OFSI);
• The United States Office of Foreign Assets Control (OFAC); and
• Any other sanctions list we are required or consider it prudent to screen against.

4.6 Ongoing Monitoring

We conduct ongoing monitoring of client relationships throughout the lifetime of the relationship to ensure that transactions are consistent with our knowledge of the client, their business, and their risk profile. We periodically review and refresh client information at the following frequency:

• High-risk clients (including PEPs): every 6 months;
• Medium-risk clients: every 12 months;
• Low-risk clients: every 24 months.

We will also conduct a review whenever a material change occurs in the client's circumstances, when identification documents on file expire, or when our monitoring systems flag unusual activity.

5. Suspicious Transaction Reporting

Under Section 14 of FIAMLA, we are legally obligated to file Suspicious Transaction Reports (“STRs”) with the Financial Intelligence Unit of Mauritius (“FIU”) where we know, suspect, or have reasonable grounds to suspect that any property, fund, or transaction is or may be connected to money laundering, terrorist financing, proliferation financing, or any other predicate offence. STRs are filed through the FIU's GoAML portal. The information contained in an STR is confidential under Mauritian law.

Important — Tipping Off:

Tipping-off occurs when a person discloses information that would alert a client or third party that:

• A suspicious transaction report (STR) has been filed with the Financial Intelligence Unit (FIU), or
• A financial crime investigation is being conducted or is about to be conducted

Our Commitment

We are legally prohibited from disclosing to any client or third party that:

• An STR has been made regarding their transactions or account
• An investigation into their activities is underway
• Any information has been shared with law enforcement or regulatory authorities

Why This Matters

Tipping-off is a criminal offence punishable by up to 2 years imprisonment and/or a fine. This prohibition protects:

• The effectiveness of investigations
• The confidentiality of reporting processes
• All clients by maintaining the integrity of our AML/CFT systems

What This Means for You

• We may request additional information or documentation from you as part of our standard compliance process without providing reasons
• We reserve the right to decline or suspend transactions that raise concerns without disclosing the underlying basis
• We will not confirm or deny whether an STR has been filed or whether an investigation is ongoing
• This policy applies to all clients regardless of their relationship with us

What is NOT Tipping-Off

You may still be asked to provide additional KYC/CDD information for legitimate compliance purposes. This does not constitute tipping-off and is part of our standard due diligence obligations.

6. What We Expect from You

Effective AML/CFT/CPF compliance is a shared responsibility. By opening and maintaining an account with MPW, you agree to support our compliance programme in the following ways:

1. Provide true, complete, and accurate identification and supporting information at onboarding and whenever requested thereafter;
2. Notify us promptly (and in any event within thirty (30) days) of any material change to information previously provided, including change of address, employment, nationality, tax residence, or PEP status;
3. Provide updated identification documents before those on file expire;
4. Respond to our requests for additional information or documentation in connection with ongoing monitoring, periodic review, or enhanced due diligence;
5. Cooperate with compliance enquiries within the timeframes specified;
6. Use your account only for lawful purposes;
7. Refrain from any activity that could amount to money laundering, terrorist financing, proliferation financing, sanctions evasion, market abuse, fraud, or tax evasion; and
8. Acknowledge that where you fail to provide required information or where we are unable to satisfy our AML/CFT/CPF obligations, we may be required to restrict, suspend, or terminate the business relationship without compensation for any resulting loss.

7. Consequences of non-compliance

Where you fail to satisfy our AML/CFT/CPF requirements, or where we determine that continued business with you would not be consistent with our compliance obligations, we may, in our discretion and in accordance with applicable law:

• Refuse to open an account or to accept you as a client;
• Restrict the value or type of permitted transactions on your account;
• Suspend access to the platform and freeze trading activity;
• Defer or refuse withdrawals pending satisfaction of outstanding documentation, subject to applicable law;
• Close the account and terminate the business relationship, returning your funds (after deduction of any sums lawfully owed) to a verified bank account in your name;
• File suspicious transaction reports and other regulatory reports with the FIU and competent authorities; and
• Block you from re-applying for an account with us.

We will not be liable for any loss, damage, cost, or expense suffered by you as a result of the exercise of any of these rights, if we have acted in good faith and in accordance with our legal and regulatory obligations.

8. Prohibited and Restricted Relationships

As part of our risk-based approach, MPW does not establish or maintain business relationships in certain circumstances. These include, without limitation:

• Anonymous accounts or accounts opened under fictitious names;
• Clients or beneficial owners listed on any applicable sanctions list;
• Shell banks, or institutions or individuals that maintain accounts with shell banks;
• Clients or beneficial owners’ resident or established in jurisdictions designated by the FATF as having strategic deficiencies in AML/CFT controls, unless enhanced due diligence requirements are satisfied;
• Clients whose source of funds or source of wealth cannot be reasonably established;
• Clients whose identity cannot be reasonably verified to our satisfaction; and
• Any other client or relationship that we determine, in our reasonable judgement, presents an unacceptable risk of money laundering, terrorist financing, or proliferation financing.

9. Internal Training and Testing

We require all our employees, including our directors and the senior management, to undertake AML/CFT/CPF training at induction and at least annually thereafter. Training covers, among other matters, the identification of suspicious activity, the obligations of the company under FIAMLA, the tipping-off rule, sanctions compliance, and the procedures for escalation to the MLRO.

Our AML/CFT/CPF programme is subject to independent compliance review on a regular basis and is also reviewed periodically by external auditors and the FSC in the course of its supervisory activities.

10. Personal Data Collected for AML/CFT/CPF Purposes

To satisfy our AML/CFT/CPF obligations, we collect and process personal data about our clients, beneficial owners, directors, and authorised representatives. This data is processed lawfully under the Data Protection Act 2017 of Mauritius and our Privacy Policy. Subject to the limitations imposed by the FIAMLA tipping-off rule and other applicable laws, you have rights of access, rectification, restriction, objection, and portability in respect of your personal data. For further information, please consult our Privacy Policy or contact our Data Protection Officer through the channels specified therein.

11. Where to Learn More

Detailed information regarding MPW's customer due diligence requirements, identification documents required, and the onboarding process is available in our KYC and Onboarding Requirements Notice, which is available for download from our website and the mobile application The following external resources provide further information about the Mauritian AML/CFT/CPF framework:

12. Contact

If you have any questions about this Policy Statement or about our AML/CFT/CPF programme more generally, you may contact us through the following channels:

Monolith Private Wealth Limited

Address: The Gardens, Ground Floor, Bagatelle Office Park, Moka 80832, Mauritius

Compliance Department / MLRO: compliance@monolithmarket.com

General Enquiries: info@monolithmarket.com

Website: www.monolithmarket.com

Please note that questions or concerns relating to specific suspicious activity should not be raised through normal customer service channels, as this may give rise to risks of tipping off. Where appropriate, contact the MLRO directly using the dedicated email address above.

13. Document Information

This Policy Statement is a public-facing summary of MPW's internal AML/CFT/CPF programme. It does not constitute the entirety of our internal policies and procedures, which are maintained in our internal AML/CFT/CPF Procedures Manual and other related internal documents available to our staff and to the FSC upon request.

We may amend this Policy Statement from time to time to reflect changes in the applicable Mauritian law and FSC regulation, the FATF Recommendations, our business model, or our internal procedures. The current version is always available for download from our website and within the mobile application. Material amendments will be communicated to clients through the platform with reasonable advance notice.

Disclaimer: This Policy Statement is provided for general informational purposes. It does not constitute legal or financial advice and does not create any contractual obligation between MPW and any reader. Where any conflict arises between this Policy Statement and applicable Mauritian law, FSC rules, or the terms of any client agreement with MPW, the law, rules, or agreement (as applicable) shall prevail. MPW reserves all its rights under applicable law and the client agreement.

Monolith Private Wealth Limited is licensed and regulated by the Financial Services Commission of Mauritius. We are committed to maintaining the highest standards of integrity, transparency, and regulatory compliance in all our business activities. Thank you for supporting us in our efforts to combat financial crime.