AML / CTF Policy

Anti-Money Laundering and Counter-Terrorist Financing Policy

Swiss Fiat AG

1. INTRODUCTION

The Swiss Fiat AML/CTF Policy is designed to prevent money laundering and the financing of terrorism by meeting Swiss and international standards, including the requirement to maintain adequate systems and controls to mitigate the risk of the Company being misused for financial crime.

It is strictly prohibited to provide products, services, or process transactions for individuals or entities listed on international sanctions lists. Compliance with all applicable laws and regulations, particularly the Swiss Anti-Money Laundering Act (AMLA) is fundamental to Swiss Fiat's operational framework.

Swiss Fiat upholds strict compliance standards and continuously enhances its processes to ensure robust adherence to AML/CTF requirements. The Company reserves the right to decline or terminate any customer, payment, or business relationship that does not align with its AML/CTF policy, irrespective of specific legal obligations.

2. MAIN OBJECTIVES

Swiss Fiat commits to:

Combating and preventing money laundering and terrorist financing by applying effective preventive measures.
Ensuring the Company is not misused for illicit purposes.
Appointing a Money Laundering Reporting Officer (MLRO) with sufficient independence and seniority to oversee compliance.
Applying a Risk-Based Approach (RBA) to identify, assess, and mitigate AML/CTF risks.
Implementing Customer Due Diligence (CDD), Know Your Customer (KYC), and Enhanced Due Diligence (EDD) procedures for high-risk clients, including Politically Exposed Persons (PEPs).
Monitoring ongoing customer activity using both automated and manual review processes.
Establishing procedures for reporting suspicious activity internally and, where required, to the Money Laundering Reporting Office Switzerland (MROS).
Retaining client and transaction records for the minimum statutory period (generally 10 years).
Providing mandatory annual AML/CTF training for all employees.

3. COMPANY COMMITMENT

Swiss Fiat is committed to:

Accepting only clients whose identities and sources of funds can be verified as legitimate.
Rejecting business relationships or accounts for anonymous, pseudonymous, or fictitious persons.
Identifying and verifying the Beneficial Owner (UBO) of each account, including full details such as name, place, and date of birth, supported by official documents.
Applying enhanced risk controls where required, including source of funds and source of wealth verification.
Monitoring transactions to identify suspicious activity and filing reports when legally required.
Providing regular AML/CTF training to all staff.
Maintaining records appropriate to the complexity and risk of each client relationship.

4. CUSTOMER DUE DILIGENCE (CDD)

As required by law, Swiss Fiat must:

Identify and verify the applicant for business and, where relevant, the beneficial owner.
Confirm whether the client acts on behalf of another party.
Establish the purpose and intended nature of the business relationship.
Conduct ongoing monitoring of all client relationships.
Establish the source of wealth (SoW) and source of funds (SoF).
Apply a client acceptance policy and admit only those who meet Swiss Fiat's compliance standards.

Anonymous accounts and accounts in fictitious names are strictly prohibited.

4.1 Prohibited Clients and Activities

Swiss Fiat will not onboard or maintain relationships with clients who:

Breach AML/CTF laws or refuse to provide required documentation.
Misuse accounts for money laundering, terrorist financing, fraud, or tax offenses.
Conduct business in high-risk jurisdictions identified by FATF, the European Commission, or Swiss authorities, including but not limited to: Afghanistan, Belarus, Cuba, Democratic Republic of Congo, Iran, Iraq, Libya, Myanmar, Nicaragua, North Korea, Somalia, South Sudan, Sudan, Syria, Venezuela, Zimbabwe.

Additionally, Swiss Fiat does not accept clients or transactions connected to:

Unregulated or offshore crypto companies;
Unregulated forex businesses;
Pyramid or Ponzi schemes, high-yield "get rich quick" schemes;
Unlicensed lotteries, gambling, or betting;
Prohibited industries such as drugs, weapons, or counterfeit goods;
NGOs or charities incorporated outside Switzerland/EU without regulation.

4.2 Sanctions Compliance

Swiss Fiat will not establish or maintain relationships with any natural or legal person designated on:

The Swiss Federal Council Sanctions List;
The United Nations Security Council Sanctions List;
The European Union Consolidated Sanctions List;
The U.S. OFAC Specialty Designated Nationals (SDN) list;

Or any other applicable sanctions list.

Swiss Fiat applies heightened scrutiny to transactions involving countries identified by FATF as non-cooperative or high-risk.

5. MONITORING FOR SUSPICIOUS ACTIVITY

Swiss Fiat applies both automated and manual monitoring systems to detect unusual or suspicious activity. Clients may be required to provide additional information regarding the purpose, counterparties, or details of specific transactions.

If clients fail to provide satisfactory information in a timely manner, Swiss Fiat may reject transactions, suspend accounts, or terminate the business relationship, in line with AMLA and SO-FIT obligations.