Anti-Money Laundering & Counter Terrorist Financing Policy Extract

Eqwire UK Limited (hereinafter referred to as “the Company”, “the Firm”, “Eqwire”, “Eqwire UK”, “we”, “our” or “us”) is an authorised e-money institution which provides its operations in partnership with Modulr group of companies (Modulr FS Limited and Modulr FS Europe Limited) for the following activities.

1. Distribution of electronic money and e-money accounts in the European Union (EU) and acting as an agent of Modulr FS Europe Limited in the EU.
2. Issuance of electronic money and offering of e-money accounts in the UK in partnership with Modulr FS Limited.
3. Providing a portal with a digital interface that enables its customers to open the electronic money account and access the account and associated services. Through this service and interface, the customer can instruct and operate additional functionality in relation to their electronic money account.

This Anti-Money Laundering & Counter Terrorist Financing Policy Extract (hereinafter referred to as “the Extract”) outlines Eqwire’s approach to preventing and detecting money laundering and countering terrorist financing. Eqwire’s obligations under all applicable Anti-Money Laundering (AML) and Countering Terrorist Financing (CTF) legislation have been considered as part of its AML & CTF policy.

Eqwire and its executive management are committed to deterring customers and outside parties from using the Firm as a conduit for illegal activity. Eqwire designed its program to provide the framework for effective compliance with laws and regulations, as well as to communicate its clear commitment to creating a strong compliance culture to the Company’s staff. The executive management recognises that the Firm’s activity is inherently exposed to the Money Laundering and Terrorist Financing (ML/TF) risk and that Eqwire needs commensurate Anti-Money Laundering/Counter-Terrorist Financing and Sanctions controls.

To ensure that Eqwire is compliant with relevant AML/CTF regulations, the business undertakes the following:

• Appointed Sergiu Sagaidac as the Firm’s Money Laundering Reporting Officer (MLRO) of whose name is communicated to the Financial Conduct Authority,
• Establishes a set of risk-based policies, procedures and internal controls,
• Keeps appropriate and accurate records, as per Money Laundering Regulations 2017 requirements,
• Develops and maintains Compliance Monitoring Plan and procedures,
• Communicates new and any updates to policies and procedures to all employees, connected persons and interested partners, in an efficient and timely fashion,
• Provides training on AML/CTF measures to all staff,
• Ensures ongoing monitoring of its customers’ identity and activities is undertaken,
• Ensures transaction and fraud prevention monitoring are conducted,
• Ensures a risk-sensitive Due Diligence is conducted on all customers prior to onboarding,
• Ensures reports of any suspicions of Money Laundering or Terrorist Financing are escalated to the MLRO. The MLRO has the authority to report suspicions to the National Crime Agency (NCA) as a Suspicious Activity Report (SAR),
• Ensures the Money Laundering risks are assessed and enhanced due diligence measures in higher-risk situations are applied,
• Receives regular MI and reports for the outsourced activity, and
• Conducts annual AML & general compliance review (audit) on all its suppliers and outsourced activities.

Eqwire recognises the responsibility it plays in ensuring the detection of financial activity by a
sanctioned individual or entity. As such, Eqwire takes a zero-tolerance approach to any positive
sanctions identified. It is also the policy of Eqwire to refuse to conduct business in any sanctioned
country or with any sanctioned individual or business when it can be reasonably established that the
match is genuine. The Company requires all its suppliers to obey this requirement and undertakes
regular independent assurance and compliance testing in this regard.

Taking into consideration UK, UN, EU, OFSI and US sanctions regulations, Eqwire uses and requires its
outsourced service providers to use tools to check and screen against these country-specific lists of
sanctions, terrorists, designated entities and individuals during the stages of customer onboarding
and execution of customer’s transactions. It is the policy of Eqwire not to establish any business
activity with the companies (individuals) which are included in these lists.

If Eqwire and/or its outsourced service provider determine that a customer is on one of the sanctions
lists or is engaging in transactions that are prohibited by the economic sanctions and embargoes
administered and enforced by regulations, the transaction will be rejected and/or the customer’s
assets will be blocked and a blocked asset and/or rejected transaction will be filed.

The MLRO is responsible for evaluating identified suspicious activity that has been reported internally
or by Modulr, and, where appropriate, reporting this to the NCA via the SAR Online reporting system.

Suspicion, as defined by the Courts, is a degree of satisfaction beyond mere speculation, which is
based on some foundation, but which does not necessarily amount to belief. “Suspicion” is the third
stage after “comfort” and “concern”.

It is a legal duty to file SARs with the NCA under PoCA. All employees are fully aware of the threats
posed by suspicious transactions and know that whenever a transaction or event that causes
suspicion. A SAR should be submitted to the MLRO or their designated officer (Deputy MLRO) as soon
as reasonably possible. The MLRO will then decide whether it should then be forwarded to the NCA.
In the absence of the MLRO, the decision is taken by their designated officer (Deputy MLRO). However,
Modulr as a regulated partner of Eqwire keeps the obligation and is entitled to disclose a SAR to the
NCA relevant to our business regardless of Eqwire’s MLRO/DMLRO decision.

Eqwire seeks to comply with both AML and Data- Protection legislation. Eqwire and/or its relevant
outsourced service provider will obtain and maintain accurate records relating to this policy so that
any interested regulatory body to have access to records in a timely fashion, and these records are
kept in such a way that they can be provided upon immediate request.