1. Introduction

To ensure compliance with international trade standards, maintain high operational standards, and minimize the company’s risk exposure, R1 London Ltd operates in accordance with applicable legislation on anti-money laundering (AML) and counter-terrorist financing (CTF). Our policies align with the legal requirements and recommendations set forth by the Financial Action Task Force (FATF) and relevant UK AML laws.

2. Risk-Based Approach

Our AML procedures follow a risk-based approach to identify, assess, and mitigate money laundering and terrorist financing risks. We take appropriate measures to prevent illicit financial activities by evaluating the risk profile of our clients and transactions.

3. Know Your Customer (KYC) & Customer Due Diligence (CDD)

We have implemented a Know Your Customer (KYC) procedure to verify our users and assess their risk levels. As a client of R1 London Ltd, you are required to:

• Provide accurate personal information as stated on your government-issued ID.
• Comply with our KYC requirements, which may include proof of identity, proof of address, and source of funds documentation.
• Respond promptly to any requests for additional information or documents.

Failure to provide the required information may result in the suspension or termination of services.

4. Monitoring of Financial Transactions

We continuously monitor financial transactions to detect suspicious activities, including but not limited to:

• Unusual transaction patterns or amounts inconsistent with a customer’s profile.
• Transactions involving high-risk jurisdictions or politically exposed persons (PEPs).
• Attempts to evade reporting thresholds.

In case of suspicious transactions or actions indicative of fraud (including refunds, chargebacks, or payment cancellations), the company may:

• Conduct an internal investigation.
• Suspend, block, or close accounts associated with suspicious activity.
• Cancel payments or suspend operations in affected accounts.

5. Reporting & Compliance with Law Enforcement

R1 London Ltd is legally obligated to report suspicious activities to the relevant financial institutions and law enforcement agencies without prior notice to the customer. To ensure compliance, the company will maintain all relevant records as required by law, including:

• Customer identification records.
• Transaction history.
• Correspondence related to AML investigations.

6. Restricted Jurisdictions

The company does not provide services to individuals located in, residing in, or with nationality from jurisdictions deemed high-risk by FATF. The restricted list may change periodically.

As of the latest update, the following jurisdictions are restricted:

• Afghanistan, Albania, Burma (Myanmar), Burundi, Central African Republic, Cuba, Iran, Iraq, Kosovo, Lebanon, Libya, Mali, Midway Islands, North Korea, Republic of the Congo, Samoa, Somalia, Sudan, Syria, United States, Vatican City State, Western Sahara, Yemen, Zambia.

7. Employee Training & Awareness

All employees of R1 London Ltd undergo mandatory AML training, covering:

• Identification of suspicious transactions and reporting procedures.
• Examples of various money laundering and terrorist financing schemes.
• Red flags and indicators of fraudulent activity.

Regular training updates will be provided to ensure compliance with evolving AML regulations.

8. Policy Review & Updates

This AML policy is subject to periodic review to ensure alignment with changes in UK AML regulations, FATF recommendations, and international compliance standards.

Last updated: 10 February, 2025