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  • 71-75 Shelton Street, Covent Garden London - UK

Introduction NBC Banq Holding Ltd Anti-Money Laundering and Know Your Customer Policy  (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of NBC  Banq Holding Ltd being involved in any kind of illegal activity. Both international and local  regulations require NBC Banq Holding Ltd to implement effective internal procedures and  mechanisms to prevent money laundering, terrorist financing, drug and human trafficking,  proliferation of weapons of mass destruction, corruption andbribery and to take action in case of  any form of suspicious activity from its customers. These requirements are created to prevent NBC  Banq Holding Ltd, our employees, partners and clients from being misused for money laundering,  terrorist financing or any other financial crime, by doing the following;


• Performing an enterprise-wide risk assessment to determine the risk profile of the Company. • Establishing AML policies and procedures.
• Implementing internal controls throughout its operations that are designed to mitigate risks of  money laundering.
• Performing know your customer (“KYC”) procedures on all customers.
• Designating a Compliance Officer with full responsibility for the AML Program. • Providing AML training to all employees.

1. Verification procedures One of the international standards for preventing illegal activity is  customer due diligence (“CDD”). According to CDD, establishes its own verification procedures  within the standards of anti-money laundering and “Know Your Customer” frameworks.
1.1. Customer identification NBC Banq Holding Ltd identifies the customer by obtaining a range of information about him/her. The verification of the identity consists of  verifying some of this information against documents or information obtained from a reliable  source which is independent of the customer. At least the following information must be  received for identification purposes: name and surname; personal identity number (if such  exists); date of birth; photograph on an official document which confirms his/her identity;  residential address; the number of the personal identification document; the expiry date of the  identification document. NBC Banq Holding Ltd will take steps to confirm the authenticity of  documents and information provided by the customers. All legal methodsfor double-checking  identification information will be used and NBC Banq Holding Ltd reserves theright to  investigate certain clients who have been determined to be risky or suspicious. NBC Banq  Holding Ltd reserves the right to verify clients identity in an on-going basis, especially when  their identification information has been changed or their activity seemed to be suspicious  (unusual for the particular client). In addition, NBC Banq Holding Ltd reserves the right  to request up-to-date documents from the clients, even though they have passed identity  verification in the past. Clients identification information will be collected, stored,  shared and protected strictly in accordance with the NBC Banq Holding ’s Privacy  Policy and related regulations. Once the clients identity has been verified, NBC Banq is  able to remove itself from potential legal liability in a situation where its Services are  used to conduct illegal activity

1.2. Sanctions We have integrated with a leading electronic data provider to fulfil the  regulatory obligations in line with the EU financial sanctions regime. Information is  aggregated from the most important sanction lists (OFAC, EU, UN, BOE, FBI, Bureau  of Industry and Security etc.) worldwide and is grouped into one category
 
1.3. Politically exposed persons In addition to the aforementioned measures, we are  integrated with the largest database of Politically Exposed Persons (PEPs), as well as  those of their family members. Whenever a client has been identified as a PEP, enhanced
due diligence measures are applied, senior management approval is necessary for  establishing or continuing, a business relationship with such a customer.

2. Compliance Officer The Compliance Officer is the person, duly authorized by NBC banq  Holding Ltd, whose duty is to ensure the effective implementation and enforcement of the  AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of NBC Banq’s anti-money laundering and counter-terrorist financing, including but not limited to: a. Collecting customers’ identification information. b. Establishing and updating  internal policies and procedures for the completion, review, submission and retention of all  reports and records required under the applicable laws and regulations. c. Monitoring  transactions and investigating any significant deviations from normal activity. d.  Implementing a records management system for appropriate storage and retrieval of  documents, files, forms and logs. e. Updating risk assessment regularly. f. Providing law  enforcement with information as required under the applicable laws and regulations. The  Compliance Officer is entitled to interact with law enforcement, which are involved in  prevention of money laundering, terrorist financing and other illegal activity.


3. Transaction monitoring NBC Banq has an ongoing live transaction monitoring process for the  purpose of detecting suspicious activity. As advised by the regulator, NBC Banq does not rely  solely on a set of prescriptive rules and thresholds; instead, it uses a risk-based approach, both in  alert generation and prioritization. The solution utilizes statistical and analytical techniques to  identify patterns of unusual and suspicious behaviors by building profiles on  each individual customer and comparing their financial activity against expected and/or peer group  norms. This is accomplished by using several powerful data analytics tools for flagging anything  that falls outside of "normal." We reserve the right to refuse to process a transaction at any stage.  Especially, when we believe that a transaction is connected in any way to money laundering or any  other type of criminal activity. In accordance with the U.K. law, we are not obliged to inform  the customer that it was reported to the corresponding bodies of the customer’s suspicious activity.

4. Reporting NBC Banq Holding Ltd has established a way in which its staff consults with  their line managers to provide evaluation for the rationale of the further disclosure; by no  means, this prevents contacting the nominated officer directly. All internal reports are  registered in an appropriate way; the nominated officer maintains a secure suspicious report  register. The framework is created in such a way, where a reasonable and faithful evaluation  is provided to each report that is received. The nominated officer assesses the risk that is  posed by a transaction or activity. In cases where there are associated accounts, an  examination of such relationships is to be carried out. If an internal review has indicated  enough grounds to knowor suspect that any benefit has been acquired and if a criminal  property exists, an external SAR report is submitted to NCA in a timely manner.

5. Record keeping Records must be kept of all customers' identity, the supporting evidence of  verification of identity (in each case including the original and any updated records) and  details of any occasional transactions. As per regulatory requirements, we keep records for  at least five years from the date a business relationship ends or from the date of the last  transaction.

6. Risk Assessment NBC Banq Holding Ltd, in line with the international requirements, has  adopted a risk-based approach to combating money laundering and terrorist financing. By adopting  a risk-based approach, NBC Banq is able to ensure that measures to prevent or mitigate money  laundering and terrorist financing are commensurate to the identified risks. This will allow  resources to be allocatedin the most efficient ways. The principle is that resources should be  directed in accordance with priorities so that the greatest risks receive the highest attention

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