Anti-Money Laundering And Counter Financing For Terrorism Policy

OTG GROUP Ltd ("OTG GROUP ", "the Company", "we", "us") is committed to the highest standards of Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT) compliance. This policy sets out the measures and procedures adopted by the Company to prevent and detect money laundering and terrorist financing activities. The Company is registered in Saint Lucia and the Grenadines and operates in accordance with the Proceeds of Crime and Money Laundering (Prevention) Act, as well as international AML/CFT standards established by the Financial Action Task Force (FATF).

The objectives of this policy are to: a) Prevent the use of the Company's services for money laundering or terrorist financing purposes. b) Comply with all applicable laws and regulations regarding the prevention of money laundering and terrorist financing. c) Establish and maintain effective internal controls and procedures to identify, assess, monitor, and manage the risks of money laundering and terrorist financing. d) Ensure that all employees and representatives of the Company are aware of their obligations under applicable AML/CFT laws and this policy.

OTG GROUP applies Customer Due Diligence measures when establishing business relationships with clients. This includes: a) Verifying the identity of the client using reliable, independent source documents, data, or information. Acceptable identification documents include a valid passport, national identity card, or government-issued driver's licence. b) Verifying the identity of any beneficial owner and taking reasonable measures to understand the ownership and control structure of legal persons. c) Obtaining information on the purpose and intended nature of the business relationship. d) Conducting ongoing monitoring of the business relationship, including scrutiny of transactions undertaken throughout the course of the relationship to ensure they are consistent with the Company's knowledge of the client. Enhanced Due Diligence (EDD) is applied where higher risks are identified, including for Politically Exposed Persons (PEPs), clients from high-risk jurisdictions, and unusually complex transactions.

All prospective clients must provide the following documentation before their account is activated: For Individual Clients: - A valid government-issued photo identification document (passport, national ID card, or driver's licence) - Proof of residential address dated within the last three (3) months (utility bill, bank statement, or government-issued correspondence) - Any additional documents requested by the compliance team For Corporate Clients: - Certificate of incorporation or registration - Memorandum and Articles of Association - Register of directors and shareholders - Proof of registered address - Identification documents for all directors, shareholders with 25% or more ownership, and authorised signatories - Board resolution authorising the opening of the account

OTG GROUP implements ongoing monitoring systems to detect suspicious activities, including: a) Automated transaction monitoring systems to flag unusual patterns of activity. b) Regular review of client profiles and transaction histories. c) Assessment of transactions that appear to have no economic or lawful purpose. d) Monitoring for transactions involving high-risk countries or jurisdictions. Where suspicious activity is identified, the Company's Compliance Officer will investigate and, where appropriate, file a Suspicious Transaction Report (STR) with the relevant Financial Intelligence Unit (FIU). The Company is prohibited from disclosing to the client or any third party that a report has been made (tipping off).

OTG GROUP maintains all records obtained through CDD measures and transaction records for a minimum period of five (5) years after the termination of the business relationship or the completion of the transaction, whichever is later. Records are maintained in a form that is retrievable and available to competent authorities upon request. Records include: - Copies of all identification and verification documents - Details of all transactions carried out - All internal and external reports relating to suspicious activities - Records of AML/CFT training provided to employees

The Company ensures that all relevant employees receive regular training on AML/CFT policies and procedures. Training covers: a) The legal requirements and obligations under applicable AML/CFT laws. b) The Company's internal policies and procedures for detecting and preventing money laundering and terrorist financing. c) How to recognise and deal with suspicious transactions. d) The procedures for reporting suspicious activities internally. Training is provided upon commencement of employment and on an ongoing basis thereafter. Records of training are maintained by the Company.

The Company has appointed a designated Compliance Officer who is responsible for: a) Overseeing the Company's compliance with AML/CFT laws and regulations. b) Receiving and investigating internal reports of suspicious activities. c) Filing Suspicious Transaction Reports with the relevant authorities. d) Ensuring that the Company's AML/CFT policies and procedures are up-to-date and effective. e) Reporting to senior management on AML/CFT compliance matters. For any questions or concerns regarding this policy, please contact us at compliance@otggroup.net.