This statement represents a certification by Infinios Financial Services B.S.C. (c) (herein after referred as “Company”, “Infinios”) to its customers, partners, third parties regarding compliance with Anti Money Laundering and Combating Terrorist Financing (hereinafter collectively referred to as “AML/CFT”) regulations. Infinios is strongly committed to prevent the use of its products and services for money laundering or terrorist financing. Accordingly, the Company complies fully with all applicable anti-money laundering and terrorist financing laws and regulations in the jurisdictions in which it does business and standards relating to combating money laundering.

Our procedures comply with applicable laws and regulations as well as the Financial Crime Regulation of the Central Bank of Bahrain (FC Module). We also monitor and adhere to other major international anti-money laundering recommendations and programs such as the Financial Action Task Force (FATF), the United Nations and European Union sanctions and the Office of Foreign Assets Control (OFAC) in addition to applicable local and international sanctions in our operating jurisdictions.

Accordingly, Infinios takes all reasonable and appropriate steps to prevent persons engaged in money laundering or the financing of terrorists or terrorist operations, from utilizing Infinios’ products and services.

AML/CFT COMPLIANCE PROGRAMME

Key components of the AML/CFT Compliance program are enshrined within the Company’s integrated management system (IMS) which is certified to the ISO 9001 Quality Management System (QMS) and the ISO 27001 Information Security Management System (ISMS). The components are as follows:

• Board of Directors approved Policy and Procedures;
• Designated Money Laundering Reporting Officer (MLRO);
• AML/CFT Risk Assessment, System, Process and Controls;
• Sanction screening;
• Ongoing AML/CFT training; and
• Independent testing.

Infinios complies with local and international regulations on AML/CFT and Sanctions requirements and prohibits doing business with:

• Companies incorporated in or trading in a prohibited country;
• Individuals residing in a prohibited country; and
• Allowing transactions to occur in a prohibited country.

Infinios’ key principles of the policy are:

• Infinios has implemented a risk-based approach using policy, procedures, processes, system, and controls to identify, manage and mitigate money laundering and terrorism financing risk and customer identification and verification procedures in line with the legal and regulatory requirements;
• Infinios will carry out the necessary procedures to determine and verify the identity of the Ultimate Beneficial Owner and necessary Customer Due Diligence (CDD) and/or Enhanced Due Diligence (EDD) measures for customers flagged as High, Medium, and Low risk;
• Infinios has implemented Know Your Employee (KYE) program containing detailed screening, monitoring and Due Diligence requirements;
• Infinios will monitor customer transactions to identify unusual activity and will report such activity to the competent authority and has implemented technology system to comply with the sanctions compliance requirements relating to customers, linked persons, and counterparties in case of transactions;
• Infinios does not onboard customers who are PEPs as part of their digital individual customer onboarding process, as per restrictions set by the Central Bank of Bahrain;
• Infinios does not accept/ open anonymous accounts or accounts in fictitious names and does not accept/ establish correspondent banking relationships with shell banks;
• Infinios will comply with all legal and regulatory requirements relating to cross border transfers;
• Infinios will arrange ongoing training of employees with regard to AML/CFT issues and their responsibilities; and
• Infinios will maintain and comply with the legal and regulatory requirements relating to record retention period.

In providing this information, Infinios does not undertake any responsibility or liability with respect to AML/CFT compliance measures that your institution may be required to take under applicable legal and regulatory requirements.

September 2021