Anti-Money Laundering Control and Financing of Terrorist and Related Activities

1. Client Acceptance Policy:

The policy adopted by BSDM Advocates is targeted to minimize the risks associated with our activities in relation to money laundering and the financing of terrorist and related activities.

Prospective clients are subject to approval on the basis of four driving criteria:

1.1) Country of Origin:

The majority of our clients represent are nationals of the European Union. In the case of third country individuals or entities, enhanced due diligence is required. In particular,these may include police conduct certificates in the case of individuals and certificates of good standing issued from the official registries of the third country jurisdictions, in the case of legal persons.

It is the Partners’ policy to refuse all prospective clients who come from jurisdictions which as per the MFSA notifications based on the publication the public documents prepared by the Financial Action Task Force (FATF) are considered to have strategic deficiencies regarding anti-money laundering and combating the financing of terrorism.

1.2) Customer Risk:

Customers who are unable to provide adequate references whether by financial institutions or professionals are never accepted as prospective clients. In specific cases, KYC documentation may need to be supplemented with additional information like certificates of good standing and/or police conduct certificates.

1.3) Risk associated with services/operations:

The nature of the business is considered before client acceptance is approved. In particular, activities which are subject to further licensing such as gaming activities, require the provision of additional information which confirm the prospective client’s expertise, experience and eligibility to carry out the proposed activities.

1.4) Nature and value of transactions:

Cash transactions other than cash amounts not exceeding Euro1,200 representing minimum share capital upon constitution of the company are not accepted.

2. Monitoring Policy:

Accepted clients are obliged by the terms of the BSDM Engagement letter to provide all necessary documentation and information as may be required from time to time. Furthermore, clients are obliged to inform the provider with any material changes to their status and to provide updated documentation in cases such as the expiration of presented passports, any changes to the proposed activities of the company, changes in personal details including but not limited to changes in residential addresses.

Prior to communications for renewals of ancillary services following incorporation, BSDM verify that passports provided are still valid. BSDM reserve the right to ask for further information where it appears that there are material changes to the standing or status of the client and/or the business activity.