This Policy establishes the Know Your Customer (KYC) and Anti-Money Laundering (AML) framework for NVC Fund Bank (NVC Fund Holding Trust). It applies to all personnel, operations, client relationships, and transactions conducted through the NVC Fund Bank platform.

The purpose of this Policy is to prevent NVC Fund Bank from being used as a vehicle for money laundering (ML), terrorist financing (TF), sanctions evasion, fraud, or any other financial crime, while enabling the institution to serve its legitimate client base efficiently.

This Policy applies to: institutional clients, correspondent banking partners, sovereign counterparties, individual account holders, business clients, and all third parties with access to NVC Fund Bank's payment infrastructure.

NVC Fund Bank's KYC/AML program is designed to align with the following standards and frameworks on a voluntary basis:

Prior to establishing any account or business relationship, NVC Fund Bank collects and verifies the following minimum information:

4.1 Standard CDD

Standard CDD applies to all clients and includes: identity verification, beneficial ownership identification, understanding the nature and purpose of the business relationship, and establishing a profile of expected transaction activity.

4.2 Enhanced Due Diligence (EDD)

EDD is mandatory for clients presenting elevated ML/TF risk, including:

• Politically Exposed Persons (PEPs), their immediate family members, and close associates
• Clients in high-risk jurisdictions (FATF grey/black list, OFAC-sanctioned)
• Clients in high-risk business sectors (cash-intensive, virtual assets, arms, precious metals)
• Correspondent banking relationships
• Clients with complex or opaque ownership structures
• Sovereign entities and government-controlled entities

EDD measures include: senior management approval, additional documentation collection, source of wealth verification, more frequent monitoring, and periodic face-to-face or video verification where appropriate.

4.3 Simplified Due Diligence (SDD)

SDD may only be applied where there is demonstrably low ML/TF risk and is subject to Compliance Officer approval. SDD does not exempt the institution from any CIP or beneficial ownership requirements.

NVC Fund Bank recognizes that PEPs present elevated corruption and ML risk due to their position of public trust. All onboarding and periodic review processes include PEP screening. The following standards apply:

• PEP status is determined at onboarding and monitored on an ongoing basis
• Foreign PEPs are treated as high-risk by default
• Domestic PEPs are risk-assessed based on their specific role and jurisdiction
• Senior management approval is required before accepting a PEP as a client
• PEP relationships are subject to annual EDD review
• Source of wealth must be independently corroborated for PEP clients

NVC Fund Bank operates a transaction monitoring program designed to detect unusual or suspicious activity. Key elements include:

• Automated monitoring of all transactions against established risk parameters and client profiles
• Alerts generated for structuring, unusual cross-border flows, rapid fund movement, and unusual counterparties
• All alerts are reviewed by the Compliance function within defined SLAs
• Suspicious Activity Reports (SARs) are filed with FinCEN where warranted
• Currency Transaction Reports (CTRs) are filed for qualifying transactions
• Records of all monitoring, alerts, and dispositions are retained for a minimum of five years
• Tipping-off to clients is strictly prohibited

NVC Fund Bank operates a zero-tolerance sanctions compliance program. The institution screens all clients, counterparties, beneficial owners, and transactions against:

• OFAC Specially Designated Nationals (SDN) list
• OFAC Sectoral Sanctions Identifications (SSI) list
• UN Security Council consolidated sanctions list
• EU consolidated sanctions list
• HM Treasury financial sanctions list

Potential matches trigger immediate account suspension and referral to the Compliance Officer. OFAC blocking and rejection reports are filed within statutory timeframes.

NVC Fund Bank retains all KYC/AML records in accordance with BSA requirements and international best practice. Client identification records, due diligence files, transaction records, and compliance decisions are retained for a minimum of five years from the date of account closure or the date of the relevant transaction, whichever is later.

Records are maintained in a secure, auditable format and are available to authorized regulatory authorities upon lawful request.

All NVC Fund Bank personnel with client-facing, transaction-processing, or compliance responsibilities complete AML/CFT training upon onboarding and at least annually thereafter. Training covers red flags for money laundering and terrorist financing, sanctions obligations, SAR filing, tipping-off prohibitions, and role-specific obligations. NVC Fund Bank maintains a culture where financial crime prevention is a shared institutional responsibility.