ANTI - MONEY LAUNDERING AND COUNTER - TERRORISM FINANCING POLICY

KOOBIZ PRIVATE LIMITED

Version: 1.1

Koobiz: KOOBIZ PTE. LTD. a corporate service provider or trustee (TCSP)

1. Introduction

Koobiz is a private limited company that provides global business support services (non-financial), including company incorporation, business maintenance, and regulatory compliance with the Accounting and Corporate Regulatory Authority of Singapore (ACRA), the Inland Revenue Authority of Singapore (IRAS), and other relevant authorities. Koobiz is committed to adhering to the highest standards in complying with Anti-Money Laundering and Countering the Financing of Terrorism (AML - CFT) requirements. This Policy sets out an overview of the applicable AML - CFT regulations and obligations.

The Board of Directors and all employees of Koobiz are required to adhere to these standards to protect the company’s reputation and prevent the misuse of Koobiz for money laundering, terrorist financing, or other illegal purposes.

Governments have enacted laws and regulations to detect and prevent money laundering and terrorist financing activities. Koobiz is committed to full compliance with all applicable laws and regulations in Vietnam.

Koobiz will periodically review and update its AML - CFT framework, objectives, and strategies, maintaining an effective AML - CFT program that reflects best practices within the financial services industry.

2. Structure and policy

Koobiz has established a Supervisory Board under the oversight of a Compliance Officer. The AML - CFT program is implemented by the AML - CFT Officer and the Money Laundering Reporting Officer (MLRO), appointed by senior management. The MLRO is responsible for ensuring full compliance with the AML - CFT program in accordance with established procedures.

Koobiz has developed detailed AML - CFT policies and procedures. This governance system ensures AML - CFT standards are integrated into the company’s daily operations. All policies and procedures are made available on an easily accessible platform and are reviewed regularly to ensure alignment with the latest AML - CFT regulations.

The scope of the policy includes:

Oversight of the Board of Directors
Policies and procedures
Internal controls
Information management systems
Personnel and training

3. Customer due diligence (KYC)

Koobiz implements a Know Your Customer (KYC) process to ensure all clients are properly identified and verified. KYC applies across all branches and business units, aiming to collect complete information on clients, transaction partners, and Ultimate Beneficial Owners (UBOs).

The process includes:

Requesting mandatory documentation
Enhanced due diligence for politically exposed persons (PEPs) and clients from high-risk industries or countries
Screening against watchlists
Continuous monitoring and updating of existing client information

Koobiz reserves the right to refuse or terminate relationships with clients if:

The true identity of the client or UBO cannot be verified, or the business nature is unclear
Fraudulent or forged documents are detected or suspected
Assets are suspected to be derived from criminal activity
Transactions involve individuals or entities suspected of terrorism or crime, or are on sanctions lists
Anonymous accounts or “shell” bank accounts are maintained

4. Regulatory reporting

Koobiz is obligated to report:

Cash transactions exceeding prescribed thresholds
Suspicious or unusual transactions
International fund transfers

All suspicious transactions must be reviewed and approved by the Compliance Officer before submission to regulatory authorities.

5. AML - CFT risk assessment

AML - CFT risk assessment includes:

Identifying inherent risks
Determining acceptable risk levels
Developing controls and mitigation measures
Assessing residual risk
Adopting a risk-based approach
Reviewing and adjusting controls according to actual risk

The MLRO and AML - CFT Officer identify, assess, and monitor money laundering and terrorist financing risks based on clients, countries/regions, products, services, transactions, and distribution channels.

6. Sanctions compliance

Compliance with sanctions lists is a critical requirement at Koobiz. The company implements restrictions and controls over the transfer of goods, services, and client funds through Koobiz products and services. The objective is to minimize legal, operational, and reputational risks. Koobiz’s AML - CFT processes related to sanctions compliance are based on laws, government regulations, international organizations, and relevant countries.

7. Record keeping

Koobiz maintains records and documentation relating to clients, client companies, and financial transactions (if any). Records are kept for a minimum of 5 years, or longer if required by law. Koobiz provides information and documentation to authorities upon legal request.

8. Training

Koobiz implements AML - CFT training programs for all employees. Training is tailored to each business unit and activity, enabling staff to recognize methods, techniques, and patterns of money laundering or terrorist financing in daily work. Training content includes policies, AML - CFT procedures, and employees’ roles and responsibilities in preventing money laundering and terrorist financing.

9. Internal controls

Koobiz maintains an effective internal control system. The AML - CFT program is independently audited by the Internal Audit Department to ensure that all policies, procedures, internal monitoring, and responsibilities are fully implemented.

This policy is an integral part of Koobiz’s Anti - Money Laundering and Counter - Terrorism Financing procedures.

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