Anti-Money Laundering & Counter Financingof Terrorism (AML/CFT) Policy

Updated JUNE 2025

Company Name: Primeliq Ltd
Jurisdiction: Saint Lucia
Note: Primeliq Ltd operates in the FX and CFD markets. As per current regulations in Saint Lucia, these activities do not require a financial services license and are not regulated by the Financial Services Regulatory Authority (FSRA).

1. Definitions & Interpretation

"the Company" – Primeliq Ltd

"the AMLCO" – Anti-Money Laundering Compliance Officer

"the Act" – Money Laundering (Prevention) Act (Revised Laws of Saint Lucia) & Counter-Terrorism Act

"Relevant employee" – Any employee of Primeliq Ltd who may possess information leading to reasonable grounds for suspicion of money laundering or terrorist financing.

"Business Relationship" – A relationship between the Company and a customer with the expectation of continuity.

"PEPs" – Politically Exposed Persons: natural persons holding or having held public office and their close associates.

"Shell Bank" – A financial institution without physical presence in any jurisdiction and not affiliated with any regulated financial group.

2. Legal Background & Offences

Under the laws of Saint Lucia, the following acts are criminal offences:

• Possession or use of criminal property

• Handling proceeds of corruption

• Arrangements involving criminal property

• Tipping-off (disclosure affecting AML investigations)

• Failure to report suspicions of money laundering

Reporting suspicions is not considered a breach of confidentiality.

3. Compliance Responsibilities

Company Responsibilities:

1. Appointment of an AMLCO

2. Verification of all clients (KYC/CDD)

3. Easy internal reporting mechanisms

4. Maintenance of identity and transaction records

5. Employee training and policy awareness

AMLCO Responsibilities:

• Promote awareness among employees

• Receive and assess internal reports

• Report suspicious transactions to the designated authority (e.g., Financial Intelligence Authority of Saint Lucia)

• Respond to inquiries from law enforcement or competent authorities

Annual AMLCO Report: To be submitted to the Board by end ofFebruary each year, including:

• Summary of internal and external reports

• Deficiencies and corrective actions

• Overview of high-risk clients and monitoring procedures

• Employee training statistics

• Update AML policies in line with legal changes
• Train new employees
• Ensure employee understanding and adherence

4. Client Onboarding & Risk-Based Approach

Before onboarding any client:

• Identify and verify identity (individual or corporate)

• Establish source of funds

• Confirm beneficial ownership
  

• Assess PEP status

• Document and retain verification data

Risk-Based Approach:

• Identify client risks based on geography,  services, complexity, transaction size

• Mitigate risks through enhanced due diligence, monitoring, and documentation

• Ongoing review of client profiles
  

Risk Categories Include:

• PEPs

• Clients from high-risk countries (FATF-listed)
  

• Offshore entities with unclear ownership
  

• Non face-to-face clients
  

• Unusual transactions or behaviour
  

5. Client Identification Procedures

Individual Clients:

• Valid passport or national ID

• Recent utility bill, bank statement, or government letter

Corporate Clients

• Certificate of Incorporation

• Company statutes or equivalent
  

• List of directors/UBOs
  

• Proof of authority to act (e.g. board resolution)

Beneficial Ownership: Company must identify natural personsultimately controlling the entity.

6. Politically Exposed Persons (PEPs)

General policy is to avoid onboarding PEPs. Ifapproved:

• Require senior management approval

• Apply enhanced due diligence
  

• Monitor account activity more closely
  

7. High-Risk Jurisdictions

Clients from countries listed by FATF asnon-compliant or under increased monitoring will be:

• Subject to enhanced due diligence

• Possibly rejected if high-risk factors     cannot be mitigated
  

8. Ongoing Monitoring

The Company will:

• Continuously monitor transactions for consistency with client profiles

• Investigate unusual activity
  

• Maintain audit trail of all investigations and findings
  

• 9. Internal Reporting & Recordkeeping

9. Examples of Money Laundering

Reporting Suspicious Transactions:

• Employees must report suspicions to the AMLCO immediately

• All reports are confidential
  

• AMLCO determines whether to escalate to     the Financial Intelligence Authority (FIA) or other relevant body
  

Records:

• Client identification data and transaction records retained for a minimum of 7 years

• Internal suspicion reports archived securely
  

10. Confidentiality & Tipping-Off

All internal reports and external disclosures must be handled confidentially. Employees must not inform clients or third parties of any AML investigation (“tipping-off”).