Know Your Counterpart (KYC) and Anti-Money Laundering (AML) Policy and Procedures

This is the policy of Julie Sandlau Vietnam to prohibit and prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable legal requirements of Vietnam.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Terrorist financing may not involve proceeds of criminal conduct but is rather an attempt to conceal either the origin of the funds or their intended use.

Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable regulations, rules and laws and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

The Company operates in compliance with ‘anti-money laundering (“AML”) and ‘know your counterpart’ (“KYC”) rules and regulations in the jurisdictions it operates in or sells products or services to and has developed the given KYC and AML Policy to protect itself from involvement in money laundering or suspicious activity as follows:

The Company is performing an enterprise-wide risk assessment to determine the risk profile of the Company.
The Company has established KYC and AML policies and procedures that have been reviewed and approved by the Company’s Directors.
The Company is implementing internal controls throughout its operations designed to reduce risks of money laundering, including designating a person responsible for AML compliance.

PROCEDURES

The Policy will be approved by the Company’s Director. All policies and procedures will be reviewed and updated or revised as needed, but no less often than annually.

Scope of this policy: apply to key customers; and key suppliers of gold, silver, platinum metals group, diamonds, and gemstone.

1. COUNTERPART IDENTIFICATION

The Company collects identifying information on each counterpart. The Company shall collect the following information (if available):

1.1.Individuals

Full Name
Telephone
Email address
Residential Address
Copy (front and back) of ID
Data collected from ID: Date of birth, Nationality
Personal photograph

1.2.Companies

Company Name
Company Address
Description of Business Activities
Government-issued business registration number or tax identification number
Authorized Representative, compare Individual of KYC process

Even after KYC approval the Company can do additional checks and ask for further documents.

2.VERIFICATION

Higher-risk suppliers or customers would include those who show any of the following characteristics:

FACTORS THAT WILL CATEGORIZE THE CUSTOMER INTO A

1 HIGH RISK CATEOGORY

2 Non-resident customer

3 Lack of knowledge of the industry

4 Requests for unusual financial terms and conditions

5 Lack of an established place of business, or an unusual location

6 Proposing a transaction that makes no sense

7 Use of banks that are unusual or distant

8 Use of non-bank financial institutions for no apparent legitimate business

purpose

9 Frequent and unexplained changes in bank accounts

10 Frequent and unexplained changes in accounting personnel

11 Unusually complex organizational structure

12 Offices located in higher risk jurisdictions

13 Involvement of third parties in transactions

14 Seeking of anonymity by conducting ordinary business through accountants, lawyers, or other intermediaries

15 Use of cash in a nonstandard manner

16 Involve politically exposed persons.

A risk assessment should be carried out for the business to identify vulnerability to involvement in money laundering or the finance of terrorism. High risk indicators or ‘red ﬂags’ should be established for screening of new customers or suppliers prior to initial transactions, and for ongoing monitoring of transactions.

Using some source for risk identification: FATF high-risk jurisdictions https://www.fatf-gafi.org/countries/#high-risk; or Watchlists and sanctions lists.

3.SUSPICIOUS TRANSACTION AND ACTIVITY REPORTS

The Company will diligently monitor transactions for suspicious activity. Transactions that are unusual will be carefully reviewed to determine if it appears that they make no apparent sense or appear to be for an unlawful purpose.

The accounting department will notify compliance staff when there are reliable transactions. Once the Compliance Officer and the accountant have finished the review of the transaction details, they will consult with the Company’s senior management to make the decision as to whether the transaction meets the definition of suspicious transaction or activity and whether any filings with law enforcement authorities should be filed.

4.APPOINTMENT OF AN AML COMPLIANCE PERSON

- AML Compliance Officer will monitoring the firm’s compliance with AML obligations, overseeing communication and training for employees.

The AML Compliance Officer will also ensure that the firm keeps and maintains all of the required AML records and will ensure that suspicious activity reports are filed. The AML

Compliance Officer is vested with full responsibility and authority to enforce the firm’s AML program.

5.REPORTING REQUIREMENTS

The following are required steps in the record keeping process:

The Company will maintain a record of identifying information provided by the customer.
The Company will record the methods and result of any additional measures undertaken to verify the identity of the customer.
All transaction and identification records will be maintained for a minimum period of five years.

6.KYC AUDIT

The Compliance Officer and the accountant are responsible for directing the annual KYC audit of the Company’s operations. The Compliance Officer and accountant will provide the audit report and all corrective action plans to the Company’s senior management for review.