Anti Money Laundering Policy

This document outlines the policy and dedication of UnityF Limited (hereafter referred to as Unity Finance) in identifying and preventing any activities related to money laundering or the financing of terrorism within the products and services it provides to its clients.

Definition

“Money Laundering” involves participating in transactions intended to obscure or disguise the nature and origin of funds obtained through illicit activities, such as fraud, corruption, organized crime, or terrorism. The specific offenses related to money laundering are outlined by national laws. The money laundering process is typically divided into three distinct phases:

Placement: moving funds away from the crime and into the financial system. This initial stage consists of physically depositing cash into banks and non-bank financial institutions, like currency exchanges. It can also include converting cash into other financial instruments, such as traveler's checks or payment orders, or purchasing high-value items that can be resold. Launderers often prefer to deposit cash in jurisdictions with lenient financial regulations, subsequently moving those funds to more regulated environments to present them as “clean.” A common strategy during this stage is "smurfing," where large sums are broken down into multiple smaller deposits to evade local regulatory reporting thresholds.

Layering: disguising the trail to hide the origin of the funds. During this phase, the objective is to distance the proceeds of criminal activities from their original source through a series of complex financial maneuvers. This might involve numerous transfers between financial institutions, early withdrawals from annuities with no regard for penalties, cash-secured loans, and letters of credit backed by fraudulent invoices or bills of lading. The intent of layering is to mask the funds' origins, disrupt any potential audit trails, and maintain anonymity. Launderers aim to complicate the tracking of “dirty” money by altering both its form and geographic location.

Integration: making the money available again to the criminal. The final stage sees the laundered proceeds reintegrated into the economy, allowing them to circulate as seemingly legitimate funds. This process effectively enables the funds to enter the financial system without raising suspicion.

This Policy is backed by a comprehensive program addressing the implementation of the following key areas:

• Adoption of a risk-based strategy
• Know Your Client (KYC) Policy and Customer Due Diligence
• Monitoring of customer activities
• Maintenance of records

Unity Finance implements a risk-based strategy to fulfill its responsibilities under Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF) regulations. This approach enables the identification, assessment, and understanding of the money laundering and terrorist financing risks faced by Unity Finance, allowing for the application of suitable mitigation measures based on the identified risk level.

• Customer-Related Risk
  Red Flags: Indicators of potential risk may include inconsistencies in identification documents, use of fictitious or stolen identities, counterfeit documents, reliance on post box addresses, previous instances of financial crime, connections to terrorism, individuals with outstanding warrants, lack of valid contact information, and discrepancies in legal entity documentation.
  Politically Exposed Persons (PEPs): This category includes individuals in significant public roles, such as heads of state, government ministers, members of parliament, leaders of political parties, supreme court justices, ambassadors, high-ranking military officials, directors of state-owned enterprises, and executives of international organizations.
• Country-Related Risk:
  The Anti-Money Laundering Directive requires enhanced due diligence for business relationships or transactions involving high-risk third countries. This involves gathering additional information about the customer and beneficial owner, tracing the origins of funds and assets, clarifying the purpose of the transaction, and obtaining senior management approval before establishing or maintaining the relationship.
• Service Risk
  Assessing the money laundering risks associated with services should take into account various factors, including those identified by regulators, governmental bodies, or other reputable sources as potentially high-risk for money laundering activities.

Unity Finance establishes business relationships with customers without the need for in-person meetings. To identify customers, Unity Finance relies on electronic data brokers, supplemented by internal checks such as detecting duplicate accounts and verifying bank account ownership. This approach ensures accurate identification and allows for the collection of essential background information regarding the purpose and nature of each customer's business with us.

Unity Finance will gather and document any additional information about customers based on the assessed risks related to money laundering, employing a Risk-Based Approach.

Moreover, Unity Finance will assess whether a customer is acting on behalf of another individual or entity as a trustee, nominee, or professional intermediary. In such cases, it is essential to obtain satisfactory evidence of the identities of any intermediaries, as well as those they represent, and to understand the specific trust arrangements involved before proceeding with services.

Beyond initial customer due diligence, Unity Finance is dedicated to the continuous monitoring of customer activities to identify any suspicious or fraudulent actions. This monitoring system integrates automated tools with manual reviews conducted by Unity Finance staff and, when necessary, external service providers. Customer accounts are assigned various status fields that enhance the effectiveness of automated monitoring.

Unity Finance has implemented a compliant process for reporting suspicious activities, allowing all employees to notify the Money Laundering Reporting Officer (MLRO) if they know of or suspect any involvement in money laundering or terrorist financing. This reporting process is structured in three essential steps:

• All staff members are expected to be vigilant in identifying any unusual or suspicious behavior.
• The reporting of any suspicious transactions or activities must conform to the relevant laws and regulations in the applicable jurisdiction.
• The Money Laundering Reporting Officer (MLRO) should receive monthly reports regarding all identified suspicious transactions or activities.

Unity Finance is required to maintain records of all documents collected for customer identification purposes in line with KYC policy requirements. This includes data from each transaction and any other information relevant to anti-money laundering efforts, as stipulated by applicable laws and regulations. Such records encompass files related to suspicious activity reports, documentation of AML monitoring, and more. All records must be retained for a minimum of five years.

UnityF Limited
Trust Company Complex, Ajeltake Road,
Ajeltake Island, Majuro, Marshall Islands MH96960
Registration Number: 127542

Email: unityflimited@gmail.com