ANTI-MONEY LAUNDERING AND

COMBATTING THE FINANCING OF TERRORISM POLICY

Last Revised: 22 June 2026

1.     Policy Statement and Commitment

1.1       This Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Policy (the Policy) establishes the framework adopted by MNA Ventures FZCO (the Company) to identify, assess, and mitigate the risks of money laundering, terrorist financing, proliferation financing, sanctions breaches, and other financial crimes in connection with its activities.

1.2       The Company is a free zone company incorporated in the United Arab Emirates (UAE) and is engaged in investment and commercial enterprise management activities. While the Company is not currently a financial institution or a Designated Non-Financial Business or Profession (DNFBP) under applicable UAE AML/CFT legislation, it recognises that its activities may present financial crime risks and has therefore adopted this Policy on a risk-based and proportionate basis, having regard to the nature, size, and complexity of its business.

1.3       The Company has adopted this Policy as a matter of good governance, risk management, and best practice. The Company is committed to maintaining appropriate controls to mitigate money laundering, terrorist financing, proliferation financing, and sanctions risks, and to supporting compliance with applicable UAE laws and internationally recognised AML/CFT standards.

2.     Effective Date

2.1 This AML/CFT Policy is effective from 22 June 2026 and supersedes any previous internal guidance on this subject.

3.     Governance and Responsibility

3.1.  The Company shall maintain appropriate internal arrangements for the implementation and periodic review of this Policy, having regard to the nature, size, and risk profile of its business. The Company may, where necessary, designate appropriate personnel or external advisors to assist with the compliance with this Policy. 

3.2.  All employees are obliged to comply with the requirements of this Policy and to escalate reasonably suspected anomalies, suspicious activity, or non-compliance to the senior management of the Company. Any employee identifying a potential concern regarding AML/CFT or any suspicious activity shall escalate such matter promptly to the senior management of the Company for assessment within one (1) business day of such occurrence.

3.3.  The Company may, in its sole discretion, provide appropriate AML/CFT awareness or guidance to relevant employees or representatives, having regard to their roles, responsibilities, and level of involvement in customer onboarding, finance, or other activities where AML/CFT risks may reasonably arise.

4.     Risk-Based Approach

The Company shall apply a risk-based approach in all customer and transaction assessments. Pursuant to this, customers shall be classified into three categories:

·       Low Risk: UAE-based customers with transparent profiles and no adverse indicators.

·       Medium Risk: Foreign customers from jurisdictions not deemed high risk, where documentation and profile are consistent.

·       High Risk: Foreign customers from high-risk jurisdictions, UAE-recognised sanctioned jurisdictions, or jurisdictions otherwise subject to applicable sanctions or heightened AML/CFT concerns.

5.              Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

5.1. Customers that pose a Medium or High Risk to the Company may be subject to proportionate CDD. Where further review is deemed necessary, customers may also be screened against applicable sanctions lists, ‘PEP’ databases, and adverse media sources at onboarding and before acceptance of the first payment. CDD may include the following:

a.     For Natural Persons:

• Verification of full name, nationality, and date of birth;
• Review of a valid passport or national identity document (where applicable);
• Proof of residential address (utility bill, tenancy contract, or equivalent); and
• Details of employment or business activity.

b.    For Legal Persons:

• Valid trade licence and constitutional documents;
• Register of shareholders and Ultimate Beneficial Owners (UBOs);
• Identification of natural persons holding 25% or more ownership or exercising control; and
• Board resolution or power of attorney evidencing authority to contract.

5.2. The Company shall conduct ongoing risk-based monitoring of customer relationships. This may include periodic reviews and re-screening of customer information, with the frequency determined by risk classification, and event-driven reviews when material changes or unusual circumstances are identified.

5.3. EDD may be utilised where customers are classified as High Risk and may include verification of source of funds and source of wealth through appropriate supporting documentation. 

6.              Sanctions Compliance

6.1. The Company shall not knowingly engage with or facilitate activities involving persons, entities, organisations, or jurisdictions that are subject to applicable United Nations sanctions or UAE sanctions restrictions.

6.2. Sanctions screening may be conducted before onboarding, prior to material transactions, and periodically on a risk-sensitive basis.

6.3. Any confirmed sanctions match shall be escalated immediately to senior management and appropriate action shall be taken in accordance with applicable law.

7.              Suspicious Activity

7.1. Where the Company identifies activity that appears unusual, suspicious, or inconsistent with the known purpose of a relationship or transaction, the matter shall be escalated for review.

7.2. The Company may seek additional information, suspend engagement, decline a transaction, or terminate a relationship where concerns cannot be satisfactorily resolved.

7.3. No employee, officer, or representative of the Company shall disclose to any person that a report has been made or is being contemplated, or that an investigation is being carried out, where such disclosure may constitute tipping-off under applicable laws.

8.              Record Keeping

8.1. The Company shall maintain records relating to due diligence, risk assessments, screening results, approvals, and relevant transactions for a minimum period of five (5) years following the end of the relationship or completion of the transaction, or such longer period as may be required by applicable law.

8.2. Records shall be maintained securely and made available to competent authorities where legally required.

9.              Review of Policy

This Policy shall be reviewed on an annual basis, or earlier where there are material changes to applicable laws, business activities, customer or risk profiles. 

This AML/CFT Policy has been approved by the senior management of the Company and adopted as of the Effective Date. The Company commits to maintaining this Policy in accordance with applicable laws and regulations.