PEXAH LTD – Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

1. Purpose of the Policy

This AML/KYC Policy is established to prevent PEXAH LTD from being used for money laundering, terrorist financing, fraud, corruption, bribery, or other illegal financial activities. The policy ensures compliance with applicable UAE federal regulations, RAK DAO rules, and international AML/CFT standards.

2. Scope

This policy applies to all customers, employees, partners, and counterparties of PEXAH LTD.

3. Customer Due Diligence (CDD)

PEXAH LTD requires all customers to undergo identity verification before engaging in trading activities. The following documents are collected via secure communication channels:

• A valid Emirates ID or Passport
• A UAE mobile number for verification
• Other supporting documents if deemed necessary

Enhanced Due Diligence (EDD) will be performed on high-risk customers such as Politically Exposed Persons (PEPs) or those with unusual transaction behavior.

4. Verification Process

Customers are required to submit identification documents and UAE mobile verification through the company’s official communication channels. All information is securely recorded and maintained in compliance with UAE data protection regulations. Verification is conducted before the execution of any trades.

5. Ongoing Monitoring

PEXAH LTD continuously monitors transactions to detect unusual or suspicious activity. Any suspicious transactions are reviewed by the Compliance Officer and reported to the UAE Financial Intelligence Unit (FIU) if required.

6. Record Keeping

All KYC records and transaction data are securely stored for a minimum of five (5) years, in accordance with UAE law. Records are updated periodically, and customers may be requested to re-submit documents when necessary.

7. Sanctions Screening

PEXAH LTD does not engage with individuals or entities listed on international sanctions lists, including UN, EU, and OFAC. All customers are screened against updated sanction databases.

8. Compliance Officer

The Compliance Officer of PEXAH LTD (currently appointed by the Board of Directors) is responsible for ensuring implementation and enforcement of this policy, reviewing suspicious activities, and liaising with regulatory authorities.

9. Risk Assessment

PEXAH LTD adopts a risk-based approach, categorizing customers based on their risk profile. Low-risk customers are reviewed every five (5) years, while high-risk customers are reviewed annually.

10. Refusal of Service

PEXAH LTD reserves the right to refuse service to any customer who fails to comply with KYC requirements or presents unverifiable or suspicious information.

11. Policy Review

This AML/KYC Policy is reviewed annually by the Compliance Officer to ensure its effectiveness and compliance with updated legal requirements.