Effective Date: 17/2/2026
Website: www.vinnexiacapital.com
Contact Email: info@vinnexiacapital.com

1. Overview

Vinnexia Capital (“the Company”) is committed to safeguarding the integrity of the financial system by preventing its services from being used to facilitate money laundering, terrorist financing, corruption, fraud, or other financial crimes. This Policy outlines the Company’s Anti-Money Laundering and Counter-Terrorist Financing (CTF) procedures, which comply with applicable laws, regulations, and international standards.

2. Purpose

The purpose of this Policy is to:
a) Define the Company’s framework for KYC, AML, and CTF compliance.
b) Ensure proper verification of clients and beneficial owners.
c) Detect, deter, and report suspicious activity.
d) Support regulatory and law enforcement efforts in combating financial crime.

3. Regulatory Commitment

Vinnexia Capital adheres to:
• Applicable regulatory obligations in its jurisdiction of establishment, including AML/CTF legislation.
• International best practices, including FATF Recommendations and relevant sanctions regimes.

4. Definitions Money Laundering and Terrorist Financing

Money Laundering is the process through which funds derived from criminal activity are converted into seemingly legitimate assets. It typically occurs in three stages:
• Placement: Introduction of illicit funds into the financial system.
• Layering: Complex transactions to obscure the source of funds.
• Integration: Funds reappear as legitimate assets or income.

Terrorist Financing refers to the provision of funds for terrorism, whether from lawful or unlawful sources.

5. Customer Due Diligence (CDD)

5.1 Identification & Verification

Before establishing an account, clients must provide documentation sufficient to verify identity and address.

Individuals:
• Government-issued photo ID (passport, national ID, driver’s license)
• Proof of address (utility bill, bank statement, etc.) dated within 3 months

Corporate Entities:
• Certificate of incorporation
• Memorandum & Articles of Association
• Registered address proof
• Identification of directors and beneficial owners
• Corporate resolution authorizing account opening

Clients whose documentation is not in Latin characters must provide notarized English translations of all documents.

6. Enhanced Due Diligence (EDD)

The Company applies EDD in cases involving:
• Politically Exposed Persons (PEPs)
• High-risk jurisdictions
• Unusual or complex transactions
• Discrepancies in documentation

EDD includes obtaining additional documentation, verifying source of funds, and conducting risk assessments.

7. Prohibited Transactions & Cash Limitation

Vinnexia Capital does not accept or pay out cash under any circumstances. Clients must ensure that all deposits and withdrawals are made through verified channels in their own name. Third-party payments are prohibited unless formally approved.

8. Transaction Monitoring

The Company continuously monitors client transactions to identify unusual patterns inconsistent with a client’s profile, history, or expected account behavior. Systems are in place to track activity, and suspicious transactions will be escalated to compliance for review.

9. Record Keeping

All client identification documents, transaction records, monitoring data, and AML documentation are retained for a minimum period of seven (7) years following account closure, in accordance with applicable regulatory and legal requirements.

10. Reporting Suspicious Activity

If a transaction or client behavior is considered suspicious, the Company will:
• Report to relevant authorities in accordance with law.
• Temporarily block or suspend the account.
• Refuse to execute the transaction under review.

The Company will not notify the client if doing so would compromise investigations or violate laws.

11. Sanctions and Watchlist Screening

Clients are screened against applicable:
• Domestic and international sanctions lists
• Terrorist financing watchlists
• Adverse media and PEP databases

Accounts that match or raise concerns may be restricted or terminated.

12. Ongoing Monitoring & Risk Review

Client relationships are regularly assessed to ensure continued compliance with risk expectations. Monitoring takes into account:
• Transaction frequency and volume
• Source and destination of funds
• Changes in client profile or geopolitical risk

13. Internal Controls & Compliance Oversight

The Company maintains a compliance department responsible for:
• Enforcement of AML/KYC policies
• Training of staff
• Conducting internal audits
• Liaising with regulators and law enforcement

14. Client Obligations

Clients must:
• Provide accurate and timely information
• Cooperate with verification requests
• Consent to ongoing monitoring

Failure to cooperate may lead to account restrictions or termination.

15. Amendments

This Policy may be updated to reflect legal, regulatory, or operational changes. The latest version is published on the Company’s official documentation portal.

16. Contact Information Compliance

Compliance Department

Vinnexia Capital

Email: support@vinnexiacapital.com

Website: www.vinnexiacapital.com