Anti-Money Laundering (AML) Policy

Policy Purpose and Commitment

At AVPros, we are committed to complying with all applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws, regulations, and regulatory guidance in South Africa. We are dedicated to preventing the use of our products and services for money laundering, terrorist financing, or any other financial crime. This policy outlines the measures we take to identify, assess, monitor, and mitigate money laundering and terrorist financing risks.

1. Legal Framework

This Anti-Money Laundering Policy is developed in accordance with applicable South African legislation, including but not limited to:

• Financial Intelligence Centre Act, 2001 (FICA)
• Prevention of Organised Crime Act, 1998 (POCA)
• Protection of Constitutional Democracy Against Terrorist and Related Activities Act, 2004 (POCDATARA)

These laws require the adoption of a risk-based approach, customer due diligence, record keeping, transaction monitoring, and the reporting of suspicious or unusual activities to the relevant authorities.

2. Customer Due Diligence (CDD)

AVPros applies Customer Due Diligence (CDD) measures before establishing a business relationship or processing certain transactions, where applicable.

Our CDD process includes:
• Verifying the identity of individual customers using reliable and independent documentation or data

• Identifying and verifying beneficial owners of legal entities, where applicable

• Understanding the nature and purpose of the business relationship

• Assessing the customer’s risk profile based on geographic location, transaction behavior, and products or services requested

3. Ongoing Monitoring

We conduct ongoing monitoring of customer relationships to ensure that transactions are consistent with the customer’s known business activities and risk profile.

Our monitoring procedures include:

• Reviewing transactions for unusual or suspicious patterns
• Updating customer due diligence information when required
• Applying enhanced scrutiny to higher-risk customers and transactions

4. Reporting Suspicious or Unusual Activity

AVPros reports any suspicious or unusual transactions or activities to the Financial Intelligence Centre (FIC) in accordance with the Financial Intelligence Centre Act.

• Reports are reviewed by the designated AML Compliance Officer
• Reports are submitted confidentially to the FIC
• Tipping-off any customer or third party is strictly prohibited

5. AML Compliance Officer

AVPros has appointed an AML Compliance Officer responsible for overseeing the implementation and enforcement of this policy.

The AML Compliance Officer is responsible for:

• Ensuring compliance with applicable AML legislation
• Reviewing suspicious activity and submitting reports to the FIC
• Overseeing customer due diligence and monitoring procedures
• Ensuring records are maintained for the legally required period

6. Employee Training and Awareness

Employees involved in customer interactions or financial transactions receive appropriate AML and CTF training to enable them to identify and report suspicious or unusual activity.

Training includes:

• Identifying suspicious transactions
• Understanding reporting obligations under South African law
• Awareness of internal AML procedures

7. Record Keeping

AVPros maintains accurate and complete records of customer identification, transactions, and reports for a minimum period of five (5) years, as required by South African law. These records are made available to regulatory authorities upon lawful request.

8. Internal Controls and Auditing

We implement internal controls designed to ensure compliance with AML obligations and to mitigate financial crime risks.

These controls include:

• Periodic internal reviews of AML procedures
• Risk assessments of customer relationships
• Ongoing evaluation of AML compliance measures

9. Beneficial Ownership

Where applicable, AVPros identifies and verifies the beneficial owners of corporate or legal entity customers in accordance with South African regulatory requirements.

10. High-Risk Customers

Customers identified as high-risk are subject to Enhanced Due Diligence (EDD) measures.

High-risk customers may include:

• Customers from jurisdictions with weak AML controls

• Politically Exposed Persons (PEPs), their close associates, or family members

• Customers engaging in complex or unusually large transactions

EDD measures may include obtaining additional customer information, verifying the source of funds, and increased transaction monitoring.

11. AML Policy Review

This policy is reviewed regularly to ensure continued compliance with South African AML legislation, regulatory guidance, and industry best practices.

Contact Information

For questions regarding this Anti-Money Laundering Policy or to report suspicious activity, please contact:

AML Compliance Officer: Kieran Connolly
Email: info@avpros.co.za
Phone:

By implementing this policy, AVPros confirms its commitment to complying with South African Anti-Money Laundering and Counter-Terrorist Financing laws. All employees and representatives are required to adhere to this policy.