AML POLICIES

AXEN CAPITAL LTD is committed to the highest standards of the Anti-Money

Laundering (AML) compliance and Counter-Terrorism Financing (CTF). The aim of the
Companies Anti Money Laundering and Terrorist Financing Policy is to actively prevent
the risks of these matters. To help the government fight the funding of terrorism and
money laundering activities, law requires all financial institutions to obtain, verify, and
record information that identifies each person opening an account. We are under the
obligation to report suspicious activities of clients relevant to money laundering.
Money laundering – the process of converting funds, received from illegal activities (such
as fraud, corruption, terrorism, etc.), into other funds or investments that look legitimate
to hide or distort the real source of funds.
THE PROCESS OF MONEY LAUNDERING CAN BE DIVIDED INTO THREE
SEQUENTIAL STAGES:
● Placement. At this stage, funds are converted into financial instruments, such as
checks, bank accounts, and money transfers, or can be used for purchasing
high-value goods that can be resold. They can also be physically deposited into
banks and non-bank institutions (e.g., currency exchangers). To avoid suspicion
by the company, the launderer may as well make several deposits instead of
depositing the whole sum at once, this form of placement is called smurfing.
● Layering. Funds are transferred or moved to other accounts and other financial
instruments. It is performed to disguise the origin and disrupt the indication of the
entity that made the multiple financial transactions. Moving funds around and
changing in their form makes it complicated to trace the money being laundered.
● Integration. Funds get back into circulation as legitimate to purchase goods and
services.
AXEN CAPITAL LTD adheres to the principles of Anti-Money Laundering and actively
prevents any actions that aim or facilitate the process of legalizing of illegally gained
funds. AML policy means preventing the use of the company’s services by criminals,
with the aim of money laundering, terrorist financing or other criminal activity.
To prevent money laundering, AXEN CAPITAL LTD neither accepts nor pays cash
under any circumstances. The company reserves the right to suspend any client’s
operation, which can be regarded as illegal or, may be related to money laundering in
the opinion of the staff.
COMPANY PROCEDURES

AXEN CAPITAL LTD will make sure that it is dealing with a real person or legal entity.
AXEN CAPITAL LTD also performs all the required measures in accordance with
applicable law and regulations, issued by monetary authorities. The AML policy is being
fulfilled within AXEN CAPITAL LTD by the following means:
● know your customer policy and due dilligence
● monitoring client’s activity
● record keeping
Know your customer: Because of the company’s commitment to the AML and KYC
policies, each client of the company has to finish a verification procedure. Before AXEN
CAPITAL LTD starts any cooperation with the client, the company ensures that
satisfactory evidence is produced or such other measures that will produce satisfactory
evidence of the identity of any customer or counterparty are taken. The company as well
applies heightened scrutiny to clients, who are residents of other countries, identified by
credible sources as countries, having inadequate AML standards or that may represent
a high risk for crime and corruption and to beneficial owners who resides in and whose
funds are sourced from named countries.
INDIVIDUAL CLIENTS
During the process of registration, each client provides personal information, specifically:
full name; date of birth; country of origin; and complete residential address. The following
documents are required in order to verify the personal information: A client sends the
following documents (in case the documents are written in non-Latin characters: to avoid
any delays in the verification process, it is necessary to provide a notarized translation of
the document in English) because of the requirements of KYC and to confirm the
indicated information:
● Current valid passport (showing the first page of the local or international
passport, where the photo and the signature are clearly visible); or
● Driving licence which bears a photograph; or
● National identity card (showing both front and back pages);
● Documents proving current permanent address (such as utility bills, bank
statements, etc.) containing the client’s full name and place of residence. These
documents should not be older than 3 months from the date of filing.
CORPORATE CLIENTS
In case the applicant company is listed on a recognised or approved stock exchange or
when there is independent evidence to show that the applicant is a wholly owned
subsidiary or a subsidiary under the control of such a company, no further steps to verify
identity will normally be required. In case the company is unquoted and none of the

principal directors or shareholders already has an account with AXEN CAPITAL LTD ,
the following documentations must be provided:
● Certificate of Incorporation or any national equivalent;
● Memorandum and Articles of Association and statutory statement or any national
equivalent;
● Certificate of good standing or other proof of registered address of the company;
● Resolution of the board of directors to open an account and confer authority on
those who will operate it;
● Copies of powers of attorney or other authorities given by the directors in relation
to the company;
● Proof of identity of directors in case he/she will deal with AXEN CAPITAL LTD on
behalf of the Customer (according to the Individual identity verification rules
described above);
● Proof of identity of the beneficial owner(s) and/or the person(s) on whose
instructions the signatories on the account are empowered to act (according to
the Individual identity verification rules described above).
MONITORING OF CLIENT ACTIVITY
In addition to gathering information from the clients, AXEN CAPITAL LTD continues to
monitor the activity of every client to identify and prevent any suspicious transactions. A
suspicious transaction is known as a transaction that is inconsistent with the client’s
legitimate business or the usual client’s transaction history known from client activity
monitoring. AXEN CAPITAL LTD has implemented the system of monitoring the named
transactions (both automatic and, if needed, manual) to prevent using the company’s
services by criminals.
RECORD KEEPING
Records must be kept of all transaction data and data obtained for the purpose of
identification, as well as of all documents related to money laundering topics (e.g. files
on suspicious activity reports, documentation of AML account monitoring, etc.). Those
records are kept for a minimum of 7 years after the account is closed.
MEASURES TAKEN
In cases of an attempt to execute transactions which AXEN CAPITAL LTD suspects that
are related to money laundering or other criminal activity, it will proceed in accordance
with the applicable law and report suspicious activity to regulating authority.
AXEN CAPITAL LTD reserves the right to suspend any client’s operation, which can be
regarded as illegal or may be related to money laundering in the opinion of the staff.

AXEN CAPITAL LTD has complete discretion to temporarily block the suspicious client
account or terminate an existing client relationship. For more information you can
contact us at support@axencapital.com