1. Preliminary Statement

Bosa Finance and Technology Ltd, bearing registration number 2023-00594 and headquartered at Ground Floor The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia, has formulated a comprehensive policy to counteract money laundering and the financing of terrorist activities.

Objective: The primary objective of this policy is to engage in the fight against the sponsorship of terrorism and money laundering. By doing so, Bosa Finance and Technology Ltd aims to mitigate the financial and legal risks associated with these illicit activities. The policy is designed to implement effective measures that prevent the occurrence of money laundering and terrorist financing within the Company.

Implementation: This document outlines the specific measures and strategic plans that Bosa Finance and Technology Ltd will deploy in pursuit of the aforementioned objective. The implementation of these measures is vital for fostering a robust defence against money laundering and the financing of terrorist activities.

Key Focus Areas: The policy places emphasis on key focus areas, including proactive measures to combat terrorism sponsorship, the prevention of money laundering, and the reduction of associated financial and legal risks. By addressing these critical aspects, Bosa Finance and Technology Ltd seeks to create a secure and compliant operational environment.

Scope: Applicable to all facets of the Company's activities, this policy underscores the importance of widespread compliance to ensure the effective prevention of money laundering and terrorist financing risks.

This document serves as a comprehensive guide, detailing the specific measures and plans that will be executed by Bosa Finance and Technology Ltd in alignment with its overarching objective.

2. Understanding Money Laundering

Money laundering, a term encompassing various processes, refers to the concealment of the origin or source of income derived from criminal activities. Its purpose is to create an appearance that the acquired revenues stem from legitimate sources.

Contrary to common misconceptions, money laundering is not confined to activities linked solely to organised crime or illegal drug trafficking. Rather, it occurs whenever an individual deals with the direct or indirect benefits derived from a crime.

The term itself, "money laundering," is somewhat misleading, as it is not limited to the laundering of money. It involves the handling of various forms of property, tangible or intangible, that represent benefits derived from criminal activities.

Typically, money laundering is a multi-stage process, often described in three key phases:

1. Placement:

• Marks the initial step where illegal funds are separated from their criminal source.
• Involves the introduction of illegal funds into the financial system or cross-border cash transfers.

2. Layering:

• Follows the successful introduction of illicit funds into the financial system.
• Requires the creation of multiple transaction layers to distance the funds from their criminal origin.
• Aims to complicate the tracking of the illegal source of the funds.

3. Integration:

• Represents the final stage, involving the placement of laundered funds back into the legal economy.
• At this point, the funds appear as legitimate net profits.
• The goal is to allow criminals to use the funds without raising suspicion that could lead to investigation or prosecution.

It is crucial to note that these stages often overlap, and not all crimes necessitate the "placement" of benefits into the financial system.

Money laundering is commonly associated with banking and money transfer services, with banks often playing a central role in laundering schemes. However, various financial and related services offered by different service providers are also susceptible to being exploited for money laundering.

Our company places a high priority on recognising the vulnerability of the services it provides in relation to money laundering, ensuring a proactive stance in preventing such illicit activities.

3. Understanding Terrorism Financing

Terrorism financing entails providing economic support for acts of terror, terrorists, or terrorist organisations, enabling them to carry out their destructive activities. Unlike other criminal organisations, the primary goal of terrorist groups is not financial gain. However, financial resources are essential for their basic operations, making the tracking and monitoring of funds a critical aspect of counter-terrorism efforts.

In the aftermath of the events on September 11th in the United States, preventing terrorist financing within the financial sector has become as crucial as combating money laundering from criminal activities.

Key Distinctions:

• Terrorism financing involves supporting future unlawful acts, whereas money laundering typically occurs after the commission of unlawful acts.
• Legally obtained property is often used to fund terrorism, while laundered funds usually originate from illegal activities.

Commonalities:

• Terrorist groups frequently engage in other forms of criminal activity, further fueling their actions.
• Both money laundering and terrorism financing necessitate collaboration with the financial sector.

The linchpin for preventing both money laundering and terrorism financing lies in the adoption of effective measures for Client Due Diligence (CDD) at the commencement of each relationship and on an ongoing basis thereafter. By implementing stringent checks, we contribute to the broader efforts aimed at dismantling the financial networks that sustain terrorist activities.

4. AML/CFT International Legislative Initiatives

The global community has united in collective efforts to combat money laundering and terrorist financing, and our company remains well-informed about the pivotal initiatives that international financial centres must adhere to. Several influential supranational bodies actively shape the landscape of anti-money laundering (AML) and countering the financing of terrorism (CFT). Here are some of the noteworthy initiatives:

1. Financial Action Task Force on Money Laundering (FATF)
    www.fatfgafi.org
    The FATF, with its Forty Recommendations and Nine Special Recommendations on terrorist financing, stands as one of the most influential bodies in this domain. Its guidance sets a robust framework for global anti-money laundering (AML) and countering the financing of terrorism (CFT) efforts.
2. Caribbean Financial Action Task Force (CFATF)
    www.cfatf-gafic.org
    Comprising states and territories in the Caribbean basin, CFATF is dedicated to implementing common counter-measures against money laundering. It operates as one of eight regional groups associated with FATF.
3. Basel Committee on Banking Supervision
    www.bis.org
    Despite its banking-focused nomenclature, the Basel Committee's influence extends across the financial sector. Its guidance emphasises the crucial role of effective Client Due Diligence (CDD) in risk management.
4. Wolfsberg Group
    www.wolfsberg-principles.com
    Comprising leading private banks globally, the Wolfsberg Group issues comprehensive recommendations on combating money laundering and a Statement on the Suppression of the Financing of Terrorism.
5. International Organisation of Securities Commissions (IOSCO)
    www.iosco.org
    IOSCO, since 1992, has actively encouraged participants to address issues related to minimising money laundering. Its Principles on Client Identification and Beneficial Ownership, adopted in 2004, complement FATF Recommendations, focusing on the role of securities regulators in monitoring industry AML compliance.
6. International Association of Insurance Supervisors (IAIS)
    www.iaisweb.org
    Giving high priority to the fight against money laundering and terrorism financing, IAIS revised its principles and insurance methodology in 2003. The updated guidelines, adopted in 2004, integrate FATF recommendations and methodology into the fight against money laundering and terrorist financing.

Our commitment includes aligning with and implementing the guidelines and recommendations set forth by these esteemed international bodies to strengthen our AML and CFT practices.

5. Additional Territorial Authority of the United States

In response to the aftermath of the 11th September events, the United States swiftly enacted the USA PATRIOT Act, a pivotal legislative measure. This act significantly broadened the territorial civil and criminal jurisdiction of the United States, effecting changes in the existing U.S. legislation to combat money laundering. Under this legislation, U.S. courts can assert jurisdiction over any foreign individual or financial institution, duly authorised under foreign legislation, if they are found to have committed offences under U.S. laws related to combating money laundering. Consequently, any foreign entity engaging in transactions involving U.S. dollars is subject to the jurisdiction of U.S. courts concerning crimes linked to combating money laundering.