Anti-Money Laundering and Counter-Terrorism Financing policy

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Purpose

(a) As part of Mondus Capital Pty Ltd (ACN 659 284 312) (Company) is required to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No.1) (Cth) (AML/CTF Rules) (together the AML/CTF Legislation).
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(b) The AML/CTF Legislation is regulated by the Australian Transaction Reports and Analysis Centre (AUSTRAC) and aims to prevent money laundering and the financing of terrorism. The Business is enrolled and registered with AUSTRAC as a designated entity under the AML/CTF Act.
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(c) The Company is an Authorised Representative of Loanmaker Pty Ltd (ACN 603 763 220) ACL 509175 (Licensee) noting that the Licensee is solely responsible for providing credit pursuant to its Australian Credit License. The Licensee is enrolled and registered with AUSTRAC.
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(d) The Company has adopted this Anti-Money Laundering and Counter-Terrorism Financing Policy (Policy) to guide and develop its program addressing its obligations (if any) under the AML/CTF Legislation and, in particular, to comply with its obligations as an Authorised Representative of the Licensee. The key objective of this Policy is to ensure the Business is complying with its legal and ethical obligations in respect to money laundering and terrorism financing.
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1. Definitions

1.1 Definitions

AML/CTF: means anti-money laundering and counter terrorism financing.
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AML/CTF Act: means the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

AML/CTF Rules: means Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No.1) (Cth).

AML/CTF Program: means the Business’s AML/CTF Program as registered with AUSTRAC.

AUSTRAC: means the Australian Transaction Reports and Analysis Centre.

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‍Board: means the Business’s Board of Directors.

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‍Business: means Mondus Capital Pty Ltd ACN 659 284 312 (Company) and any related bodies corporate that might exist from time to time including as an

Authorised Representative of Loanmaker Pty Ltd (ACN 603 763 220 ACL 509175.

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‍Compliance Officer: means the Employee(s) who are responsible for managing the compliance of the Business and the adherence to the Policy.

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‍Employee: means any of the Business employees, representatives, officers or directors.
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2. This policy

2.1 Effective date

This policy is effective from 10/09/2024.

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‍2.2 Supersedes

This document supersedes all previous documents, practices, and policies relevant to the AML/CTF reporting.

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‍2.3 When does this policy apply?

This Policy applies to applies to all Employees of the Business and encompasses all business operations and customer interactions.

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‍2.4 Policy review

This Policy will be reviewed on an annual basis by the Compliance Officer.
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3. Background

3.1 Summary of AML/CTF

The AML/CTF Act and AML/CTF Rules provides the means to help deter, detect and disrupt money laundering and terrorism financing.
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Money laundering is the process of dealing in, disguising or concealing the origin of illicit funds to make it appear that the funds come from legitimate source.
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Terrorism financing refers to the means and methods that terrorist organisations use to finance activities that pose a threat to national and international security.

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‍3.2 Principles

The Business is committed to:

(a) complying with its obligations (if any) under AML/CTF legislation;

(b) safeguarding its customers and Employees’ from becoming a victim of, or unintentional accomplice to AML/CTF risks; and

(c) ensuring its AML/CTF Program (if any) is fit for purpose and continually evolving to meet market requirements, noting that at the date of this Policy there is no specific obligation on the Business to lodge any AML/CTF Program with ASIC as this obligation remains with the Licensee.
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4. Our AML/CTF Policy

4.1 General

The Business is committed to implementation, operating and maintaining an AML/CTF Program (to the extent it is required to under the AML/CTF Act and AML/CTF Rules given it is an Authorised Representative of the Licensee) which mitigates AML/CTF risks and is compliant with AML/CTF legislation.
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The AML/CTF Act requires us to prepare and comply with our AML/CTF Program which comprises of two parts, being Part A and Part B.
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Part A comprises the Business’s methods of governance, policy and risk assessment and Part B comprises of customer identification and risk rating.
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The Business implements a risk-based AML/CTF Program that includes:
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(a) identifying, assessing and mitigating money laundering and terrorism financing risks;
(b) document the risk assessment process and findings;

(d) ensuring staff are aware of how to identify and report suspicious activities;

(e) conducting regular independent reviews of its AML/CTF Program to ensure its effectiveness; and

(f) updating the AML/CTF Program as necessary based on review findings.
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4.2 Part A of the AML/CTF Program

The primary purpose of Part A is to identify, mitigate and manage risk for which the Business may reasonably face in the course of its business. The compliance of Part A and considering the AML/CTF risks are ultimately reported to the Board and is independently reviewed.
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The key requirements the Business will meet under Part A of its AML/CTF Program is as

follows:
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(a) Oversight required by the Board and its executives;

(b) The appointment of a Compliance Officer;

(d) AML/CTF risk assessment and awareness and how those risks interact with the

Business’s products, customers, and systems;

(e) Training and awareness;

(f) Employee due diligence;

(g) Independent review; and

(h) AUSTRAC relationship and feedback.
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4.3 Part B of the AML/CTF Program

Part B requirements refers to our customer identification procedures, also known as “KYC” or know your customer procedures. KYC procedures will specify:
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(a) What customer information is to be collected and verified;

(b) How information is to be collected and verified;

(d) How the Business responds to customer information discrepancies; and

(e) How the Business decides that additional information is to be collected.
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Customer’s personal information will be dealt with by the Business in accordance with its Privacy Policy.
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5. Compliance

5.1 Employees

All Employees have a role in ensuring compliance with the Business’s AML/CTF Program. Any Employee that knowingly or recklessly breaches the AML/CTF Program or AML/CTF Policy standards and procedures will be subject to disciplinary procedures.

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5.2 Record Keeping

The Business is required to keep full and accurate records of their AML/CTF obligations. They must be maintained and stored adequately.

Records pertaining to the AML/CTF Program must include records of:
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(a) The date of adoption;

(b) Board minutes approving the program;

(d) Any changes to the program.
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The records must be kept for seven years after the day the AML/CTF Program ends and is no longer in use. When a change is made, records must be retained for seven years after the change no longer has effect.
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5.3 Reporting

The Business will endeavour to submit regular compliance reports to the Licensee (and if required by law, to AUSTRAC) and ensure all reporting obligations are met timely and accurately.

5.4 Penalties for non-compliance

Failure to comply with this Policy and AML/CTF Program requirements can result in significant penalties, including fines and imprisonment. Disciplinary actions will be taken against Employees who fail to adhere to this policy.
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If required, steps will be taken to comply with any law that requires such matters to be reported to a law enforcement agency. The Business will take all steps to cooperate with any law enforcement agency responsible for investigating or enforcing AML/CTF legislation.
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6. Contact

Compliance Officer

Officer: Nir Davidson

Email: nir@mymondus.com

Phone: 0422 362 290