FATCA and CRS Notice

1. Purpose of This Notice

Monolith Private Wealth Limited (the “Company”, “MPW”, “we”, “us”, or “our”) is committed to compliance with international tax transparency standards. As a financial institution incorporated in the Republic of Mauritius and licensed by the Financial Services Commission, we are subject to two key international tax-information reporting frameworks:

• The United States Foreign Account Tax Compliance Act (“FATCA”); and

• The OECD Common Reporting Standard (“CRS”).

This Notice is intended to explain, in plain language:

• What FATCA and CRS are and why they matter to you;

• Why we ask you for tax-residency information at onboarding and during the relationship;

• What information we may be required to report about you and your account;

• Where that information goes and how it is used; and

• What we expect of you in supporting our compliance with these frameworks.

This Notice is for general information and does not constitute tax, legal, or financial advice. If you are uncertain about your tax position or the tax consequences of opening or maintaining an account with us, please consult an independent qualified tax adviser.

2. What Are FATCA and CRS?

2.1 FATCA

FATCA is United States legislation enacted in 2010 that requires foreign (non-U.S.) financial institutions to identify accounts held by U.S. taxpayers and to report certain information about those accounts to the U.S. Internal Revenue Service (“IRS”). Mauritius and the United States entered into an Intergovernmental Agreement (the “Mauritius-U.S. IGA”) in 2013 to implement FATCA, which means that Mauritian financial institutions report directly to the Mauritius Revenue Authority (“MRA”), and the MRA exchanges the information with the IRS.

Under FATCA, a “U.S. Person” includes, among others:

• Any U.S. citizen, including dual citizens, regardless of where they live;

• Any individual who is a lawful permanent resident of the United States (Green Card holder);

• Any individual who satisfies the U.S. "substantial presence" test in respect of a calendar year;

• U.S. corporations, partnerships, estates, trusts, and other entities formed or organised in the United States; and

• Certain other persons defined under U.S. tax law.

2.2 CRS

The Common Reporting Standard (“CRS”) is a global tax-transparency framework developed by the Organisation for Economic Co-operation and Development (“OECD”). It calls on participating jurisdictions to automatically exchange financial-account information among tax authorities, with the goal of combatting cross-border tax evasion. Mauritius was an early adopter of CRS, committing to the automatic exchange of information from 2018. CRS is implemented in Mauritius through the Income Tax (Common Reporting Standard) Regulations and the Multilateral Competent Authority Agreement (MCAA).

Under CRS, financial institutions like MPW are required to identify accounts held by tax residents of “Reportable Jurisdictions” and to report certain information about those accounts to the MRA, which exchanges the information with the tax authorities of the jurisdictions in which the relevant clients are tax-resident.

Note: Unlike FATCA, which targets U.S. taxpayers specifically, CRS applies to tax residents of any participating jurisdiction other than Mauritius. The list of Reportable Jurisdictions under CRS is published and updated periodically by the MRA.

3. Why This Applies to MPW and to You

3.1 MPW as a Reporting Financial Institution

MPW is classified as a “Reporting Financial Institution” under both FATCA (Mauritius-U.S. IGA) and CRS (OECD Common Reporting Standard). This means that:

• MPW is registered with the U.S. IRS under FATCA and has been issued a Global Intermediary Identification Number (“GIIN”);

• MPW is registered with the MRA as a Reporting Financial Institution for both FATCA and CRS purposes;

• MPW is required to identify the tax residency of all its clients and, where applicable, their beneficial owners or controlling persons;

• MPW is required to submit annual reports to the MRA in respect of reportable accounts; and

• MPW is required to maintain records supporting its reporting for a minimum period prescribed by Mauritian regulation.

3.2 Implications for Clients

As a client (or prospective client) of the Company, FATCA and CRS mean that:

1. You will be asked to complete a self-certification of your tax residency at the time of account opening;

2. You will be asked to provide information including your Tax Identification Number (“TIN”) for each jurisdiction in which you are tax-resident, your country of birth, and other related identifying information;

3. If you are an entity (company, partnership, trust, foundation, or other arrangement), you will also be asked to classify the entity under FATCA and CRS, and to identify the natural persons who are the entity's beneficial owners or controlling persons;

4. You will be asked to notify MPW promptly of any change in your tax-residency status or in the information you have previously provided;

5. Where you are identified as a tax resident of the United States (or as a U.S. Person under FATCA) or as a tax resident of a CRS Reportable Jurisdiction other than Mauritius, certain information about your account may be reported by MPW to the MRA on an annual basis; and

6. The MRA will, in turn, exchange that information with the tax authorities of the jurisdictions to which the reporting relates.

4. Information We Collect

To satisfy our FATCA and CRS obligations, we collect the following information from our clients. This information is captured through the self-certification form, which is integrated into the onboarding process on the MPW online platform and mobile application.

4.1 Individual Clients

4.2 Entity Clients

For corporate, partnership, trust, foundation, or other entity clients, additional information is collected:

5. What the Company Reports

Where your account is determined to be a reportable account under FATCA or CRS, MPW is required to report certain information about you and your account to the MRA on an annual basis. The MRA then exchanges that information with the tax authority of the jurisdiction to which the report relates. The information typically reported includes:

• Your full name and current address;

• Jurisdiction(s) of tax residence;

• Tax Identification Number(s);

• Date and place of birth (for natural persons);

• Account number;

• The name and identifying number of MPW as the Reporting Financial Institution;

• The account balance or value as at the end of the relevant calendar year (or at the closing of the account during the year);

• Gross amount of interest, dividends, and other income paid or credited to the account during the year; and

• Gross proceeds from the sale or redemption of financial assets paid or credited to the account during the year.

Important: Reporting under FATCA and CRS is a legal obligation that we cannot decline to fulfil. The decision as to whether an account is reportable is determined by the application of the law to the facts you provide and is not at the discretion of MPW. We will, however, take all reasonable steps to ensure that reporting is accurate and that no account is reported except where required by the framework.

6. Reporting Cycle

MPW conducts its FATCA and CRS reporting on the following indicative cycle. Specific dates are confirmed by the MRA each year and MPW adjusts its timetable accordingly.

7. Change in Circumstances

You are required to notify MPW promptly — and in any event within thirty (30) days — of any change in your circumstances that could affect your status under FATCA or CRS. "Change in circumstances" includes, without limitation:

• Acquisition or loss of U.S. citizenship or U.S. residence (including becoming or ceasing to be a Green Card holder);

• Change in country of tax residence or acquisition of additional country(ies) of tax residence;

• Change in principal residence address;

• Change in the legal form, ownership, or controlling persons of an entity client;

• Issuance of a new TIN by any jurisdiction;

• Any material changes in the entity's classification (e.g., from an Active NFE to a Passive NFE under CRS); and

• Any other change that may render the previously provided self-certification incorrect or incomplete.

Upon notification of a change in circumstances, MPW will request a refreshed self-certification and, if needed, additional supporting documentation. We may suspend or restrict account activity until the refreshed self-certification has been received and validated.

8. What We Expect of You

Your cooperation is essential for MPW to satisfy its FATCA and CRS obligations. By opening and maintaining an account with us, you agree to:

• Complete the self-certification form truthfully, accurately, and completely at onboarding;

• Provide supporting documentation where requested (for example, certificate of tax residence, IRS forms W-9 or W-8 series, or other equivalent documents);

• Notify MPW within 30 days of any change in circumstances that may affect your FATCA or CRS status;

• Respond to MPW's periodic requests for refreshed self-certification within the timeframes specified;

• Acknowledge that the information provided may be reported to the MRA and, through the MRA, to one or more foreign tax authorities; and

• Acknowledge that providing false, incomplete, or misleading information may constitute a criminal or administrative offence under Mauritian law or the law of any other jurisdiction concerned.

9. Consequences of Failing to Provide a Self-Certification

Where you fail to provide a valid self-certification, or where the self-certification is incomplete or appears to be inaccurate, MPW may, depending on the framework concerned:

• Decline to open or continue your account;

• Treat the account as "undocumented" under CRS (which carries specific reporting consequences and may itself trigger reporting);

• Apply the FATCA presumption rules, which may include withholding obligations in respect of certain U.S.-source payments;

• Restrict transaction types until a valid self-certification is received; or

• Terminate the business relationship after reasonable notice.

Critical: Providing false, incomplete, or misleading information on a FATCA or CRS self-certification is a serious matter. It may give rise to criminal liability under Mauritian law (including under the Income Tax Act 1995, FIAMLA, and other applicable legislation) and may also expose you to consequences under the laws of your country of tax residence and/or under U.S. law in relation to FATCA. If you are unsure about how to answer any question on the self-certification, you should consult an independent qualified tax adviser before completing the form.

10. Personal Data Collected for FATCA and CRS

Personal data collected for FATCA and CRS purposes is processed in accordance with the Data Protection Act 2017 of Mauritius and MPW's Privacy Policy. The lawful basis for this processing is MPW's compliance with legal obligations under Mauritian tax law and the international agreements to which Mauritius is a party.

10.1 Recipients of Data

Information reported under FATCA and CRS is provided to:

• The Mauritius Revenue Authority ("MRA");

• Through the MRA, to the U.S. Internal Revenue Service ("IRS") under the Mauritius-U.S. IGA in relation to FATCA reporting; and

• Through the MRA, to the competent tax authorities of CRS-participating jurisdictions in which the client is tax-resident.

10.2 Retention

Records supporting FATCA and CRS reporting (including self-certifications, supporting documentation, and reporting submissions) are retained by MPW for a minimum period of seven (7) years from the relevant reporting year, consistent with our general record-keeping policy and applicable Mauritian regulation.

10.3 Data Subject Rights

Subject to limitations imposed by Mauritian tax law and international agreements, you have the rights of access, rectification, and (in limited circumstances) restriction in respect of your personal data. For further information, please consult our Privacy Policy or contact our Data Protection Officer through the channels published therein.

Limitation: Certain data subject rights — in particular the rights of erasure, restriction, and objection — are restricted in the FATCA/CRS context because the processing is mandated by law. We are not able to delete or restrict the processing of records that we are required to maintain and report under FATCA and CRS.

11. Contact

If you have questions about this Notice, about the FATCA/CRS self-certification process, or about your specific position, please contact us through the following channels. Please note that MPW employees can answer factual questions about the FATCA and CRS frameworks and MPW's procedures but cannot provide individual tax advice — for personal tax advice you should consult an independent qualified tax adviser.

Monolith Private Wealth Limited

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

Compliance / Tax Reporting: fatca-crs@monolithmarket.com

General Enquiries: info@monolithmarket.com

Website: www.monolithmarket.com

12. Document Information and Updates

This Notice is published by the Company for general informational purposes. We may amend this Notice from time to time to reflect changes in the applicable Mauritian law, MRA guidance, IRS guidance, OECD CRS standards, or MPW's 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.

1. "Controlling Persons*" means the natural person(s) who exercise control over an entity. For a trust, this includes the settlor(s), trustee(s), protector(s) (if any), beneficiary(ies) or class(es) of beneficiaries, and any other natural person exercising ultimate effective control. For other entities (companies, partnerships, foundations), this means natural persons holding ≥25% ownership interest or, if no such person exists, the senior managing official. This definition aligns with the OECD CRS and Mauritius Revenue Authority CRS Guidance Notes.*↩︎