Anti-Money Laundering (AML) Policy ScoreCM Ltd.

1. Introduction

ScoreCM Ltd. (Score Capital Markets Limited) is committed to maintaining the highest standards of Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) compliance. This policy delineates the principles and procedures that the Company adheres to in order to prevent the misuse of its services for money laundering or terrorist financing purposes.

2. Regulatory Framework

The Company operates in strict compliance with the AML and CFT regulations of the Commonwealth of Dominica, including but not limited to:

• The Money Laundering (Prevention) Act, as amended.
• The Financial Intelligence Unit Act.
• Relevant guidelines and recommendations issued by international bodies such as the Financial Action Task Force (FATF).

3. Objectives

The objectives of this AML policy are to:

• Prevent and detect money laundering and terrorist financing activities.
• Ensure full compliance with all applicable AML and CFT laws and regulations.
• Protect the integrity of the financial system.
• Maintain the Company’s reputation and avoid any involvement in illicit activities.

4. Scope

This policy applies to all employees, directors, officers, and agents of ScoreCM Ltd., as well as any third parties acting on behalf of the Company.

5. Key Components of the AML Program

5.1 Customer Due Diligence (CDD)

Identification and Verification: The Company shall verify the identity of all customers using reliable, independent source documents, data, or information.

Enhanced Due Diligence (EDD): For higher-risk customers, the Company shall implement enhanced due diligence measures, which may include obtaining additional information and monitoring the customer’s activities more closely.

Ongoing Monitoring: The Company shall continuously monitor customer transactions and activities to identify and report any suspicious behavior.

5.2 Risk Assessment

The Company shall conduct regular risk assessments to identify and mitigate potential AML and CFT risks. This includes assessing the risks associated with customer types, geographic locations, products, and services.

5.3 Reporting of Suspicious Activities

Employees are required to report any suspicious transactions or activities to the Compliance Officer immediately. The Compliance Officer shall investigate and, if necessary, file a Suspicious Activity Report (SAR) with the Financial Intelligence Unit (FIU) of Dominica.

5.4 Record Keeping

The Company shall maintain all records of transactions, customer identification, and due diligence documentation for a minimum of five years, or longer if required by law.

5.5 Training and Awareness

The Company shall provide ongoing training to all employees on AML and CFT regulations, the identification of suspicious activities, and the procedures for reporting such activities.

6. Compliance Officer

The Company has appointed a dedicated Compliance Officer responsible for overseeing the AML program. The Compliance Officer’s duties include:

• Ensuring compliance with AML laws and regulations.
• Conducting regular audits of the AML program.
• Providing training and support to employees.
• Liaising with regulatory authorities and law enforcement.

7. Sanctions and Penalties

Non-compliance with this AML policy may result in disciplinary action, including termination of employment or business relationships, and may expose individuals and the Company to legal sanctions.

8. Review and Updates

This AML policy shall be reviewed and updated regularly to ensure it remains effective and compliant with current laws and regulations.

9. Conclusion

ScoreCM Ltd. is unwavering in its commitment to preventing money laundering and terrorist financing. By adhering to this AML policy, the Company aims to protect itself, its employees, and its clients from the risks associated with financial crimes.