AML Policy

Anti-Money Laundering (AML) Policy

Investir Pour Ton Avenir

1. Introduction

This Anti-Money Laundering (AML) Policy outlines the principles, rules, and internal control procedures implemented by Investir Pour Ton Avenir (hereinafter referred to as “the Company”) to prevent and detect any form of money laundering and terrorist financing activities in accordance with applicable French and European legislation, including but not limited to the French Monetary and Financial Code, the EU AML Directives, and guidance from the Autorité des Marchés Financiers (AMF).

2. Purpose

The purpose of this Policy is to establish a robust framework that mitigates the risks of the Company being used for money laundering or terrorist financing, and to ensure full compliance with regulatory obligations. It also serves to protect the integrity, reputation, and operations of the Company.

3. Scope

This Policy applies to all directors, officers, employees, consultants, contractors, agents, and any other persons associated with the Company. It extends to all branches, subsidiaries, and affiliated entities operating under the brand of Investir Pour Ton Avenir, regardless of their location.

4. Definitions

• Money Laundering: The process of concealing the origins of illegally obtained money, typically by means of transfers involving foreign banks or legitimate businesses.

• Terrorist Financing: The provision or collection of funds with the intention or knowledge that they will be used to carry out acts of terrorism.

• Customer Due Diligence (CDD): The process of identifying and verifying the identity of customers and assessing the risks associated with them.

5. Regulatory Framework

This Policy is guided by the following legislation and guidelines:

• French Monetary and Financial Code (Code Monétaire et Financier)

• EU Directive 2015/849 (Fourth AML Directive), Directive (EU) 2018/843 (Fifth AML Directive), and subsequent amendments

• Autorité des Marchés Financiers (AMF) AML/CFT guidelines

• Financial Action Task Force (FATF) Recommendations

6. Risk-Based Approach

The Company adopts a risk-based approach (RBA) to AML compliance. This involves identifying, assessing, and understanding the money laundering and terrorist financing risks the Company faces, and applying appropriate mitigation measures proportionate to the level of risk.

7. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

The Company performs CDD measures before establishing a business relationship, including:

• Identifying the customer and verifying their identity

• Identifying the beneficial owner(s) and verifying their identity

• Understanding the nature and purpose of the business relationship

• Conducting ongoing monitoring

EDD is applied to high-risk customers and situations, such as politically exposed persons (PEPs), customers from high-risk third countries, and complex ownership structures.

8. Suspicious Activity Monitoring and Reporting

The Company maintains systems for monitoring transactions to detect unusual or suspicious activity. Any employee who becomes aware of such activity must promptly report it to the designated AML Compliance Officer. The Compliance Officer is responsible for reporting suspicious transactions to TRACFIN, the French financial intelligence unit.

9. Record Keeping

All records relating to CDD, transactions, internal and external reports, and training must be retained for a minimum period of five (5) years from the end of the business relationship or the date of the transaction.

10. Training and Awareness

The Company ensures that all relevant personnel receive regular training on AML/CFT obligations, red flags, procedures for detecting and reporting suspicious activity, and updates to relevant legislation.

11. Internal Controls and Governance

The AML compliance function is independent and reports directly to the senior management of the Company. The Board of Directors has ultimate responsibility for ensuring that the Company complies with all AML/CFT obligations.

12. Sanctions Compliance

The Company complies with all applicable international sanctions regimes. Transactions involving sanctioned individuals or entities are strictly prohibited.

13. Review and Updates

This Policy is reviewed at least annually and updated as necessary to reflect changes in legislation, regulation, and business activities.

Approved by:

Board of Directors, Investir Pour Ton Avenir