Wolfsberg CBDDQ — NVC Fund Bank

Section 1 — General Information

Question	Response
Legal name of the institution	NVC Fund Holding Trust (operating as NVC Fund Bank)
Legal entity type	Sovereign Estate Trust — Supranational Financial Institution
Country of incorporation / establishment	United States of America
Primary regulator / supervisory authority	Operates under sovereign estate trust authority. Voluntarily adopts applicable US financial regulatory standards including BSA/AML obligations. ISO 20022 certified messaging framework in place.
Is the institution publicly listed?	No. NVC Fund Holding Trust is a private estate trust institution.
SWIFT BIC code	Not currently assigned. Correspondent SWIFT messaging facilitated through authorized correspondent banking partners.
Primary currency	USD. Multi-currency capable: EUR, GBP, NVCT (proprietary stablecoin), AFD1, and other ISO 4217 currencies.
Website	nvcfundbank.com
Financial crimes compliance contact	Compliance Division — compliance@nvcfundbank.com

Section 2 — AML / CFT Program

Question	Response
Does the institution have a documented AML/CFT policy?	Yes — NVC Fund Bank maintains a formal AML/CFT Policy reviewed annually by the compliance function.
Is the AML program approved by senior management or the board?	Yes — Approved by the executor (Rev. Frank Ojogwa Ekejija) and the senior compliance officer.
Is there a designated AML Compliance Officer?	Yes — Compliance oversight: Dr. Hashiru OL. Ajadi Muniru, Ph.D., FCSI, DMS, CFA
Does the institution have an independent audit of its AML program?	Yes — Independent review is conducted as part of the institution's annual compliance cycle.
Is employee AML training conducted?	Yes — All personnel with client or transaction-facing responsibilities complete AML/CFT training upon onboarding and annually thereafter.
Does the AML program include a risk-based approach?	Yes — Client onboarding and transaction monitoring use a risk-tiered framework. High-risk clients and jurisdictions trigger enhanced due diligence.
Does the institution have policies to comply with the FATF 40 Recommendations?	Yes — NVC Fund Bank voluntarily aligns its AML/CFT program with FATF Recommendations. Documentation available upon execution of NDA.

Section 3 — Know Your Customer / Customer Due Diligence

Question	Response
Does the institution have documented KYC policies and procedures?	Yes — Formal KYC Policy governs all client onboarding. Available to correspondent partners upon request.
Does the institution conduct Customer Due Diligence (CDD) on all clients?	Yes — CDD is conducted for all institutional clients, correspondent banks, sovereign counterparties, and high-value individuals prior to account opening.
Is Enhanced Due Diligence (EDD) applied to high-risk clients?	Yes — EDD is applied to clients in high-risk jurisdictions, PEPs, clients with complex ownership structures, and those in sectors with elevated ML/TF risk.
Does the institution verify the identity of beneficial owners?	Yes — Beneficial ownership verification is a mandatory component of CDD for all legal entity clients.
Does the institution collect source of funds / source of wealth information?	Yes — Source of funds and source of wealth declarations are required for institutional onboarding and large-value transactions.
Does the institution perform ongoing monitoring of existing client relationships?	Yes — Periodic relationship reviews are conducted based on risk tier. High-risk relationships are reviewed annually; standard relationships every three years.
Does the institution have a process for updating KYC documentation?	Yes — KYC files are refreshed upon material changes and on a scheduled cycle by risk rating.

Section 4 — Sanctions Screening & OFAC Compliance

Question	Response
Does the institution have a formal sanctions compliance program?	Yes — A formal sanctions compliance program is maintained covering OFAC, UN Security Council sanctions, and applicable EU sanctions lists.
Does the institution screen clients and transactions against sanctions lists?	Yes — All onboarding and transaction activity is screened against OFAC SDN, consolidated UN, EU, and HM Treasury sanctions lists in real time.
Does the institution have procedures for handling potential sanctions matches?	Yes — Escalation procedures are in place. Potential matches trigger account freeze and referral to the Compliance Officer within 24 hours.
Does the institution screen for sanctioned jurisdictions (not just named persons)?	Yes — Jurisdiction-level screening is applied. Transactions involving OFAC-sanctioned jurisdictions (Cuba, Iran, North Korea, Syria, Russia designated entities) are blocked.
Does the institution have a process for filing OFAC reports / blocking reports?	Yes — OFAC blocking reports and rejection reports are filed within the required 10-day window.

Section 5 — Politically Exposed Persons (PEP)

Question	Response
Does the institution have a PEP identification and screening process?	Yes — PEP screening is conducted at onboarding and on an ongoing basis for all client relationships.
Does the institution apply EDD to PEP clients?	Yes — All PEPs (domestic, foreign, and international organizations) are subject to Enhanced Due Diligence, including senior management approval for account opening.
Does the institution include immediate family members and close associates of PEPs?	Yes — PEP screening extends to immediate family members and known close associates in accordance with FATF standards.
What PEP screening databases are used?	Commercial PEP and adverse media screening databases supplemented by manual review of credible public sources. Specific vendor details available under NDA.

Section 6 — Transaction Monitoring & SAR Filing

Question	Response
Does the institution have a transaction monitoring system?	Yes — Automated transaction monitoring is in place. Alerts are generated for unusual patterns, threshold breaches, and high-risk indicators.
Does the institution file Suspicious Activity Reports (SARs)?	Yes — SARs are filed with FinCEN when warranted. The SAR decision process involves the Compliance Officer and is documented.
Does the institution have a Currency Transaction Report (CTR) filing process?	Yes — CTRs are filed for qualifying cash transactions in accordance with BSA requirements.
Is there a tipping-off prohibition in place?	Yes — Staff are trained on the prohibition against tipping off clients who are subject to SAR filings or investigations.

Section 7 — Correspondent Banking Specific Controls

Question	Response
Does the institution conduct due diligence on its own correspondent banking partners?	Yes — All correspondent banking partners are subject to formal due diligence prior to establishment of any relationship, including review of their regulatory standing, AML program, and beneficial ownership.
Does the institution prohibit relationships with shell banks?	Yes — NVC Fund Bank will not establish or maintain correspondent relationships with shell banks as defined by the USA PATRIOT Act.
Does the institution have controls on nested correspondent banking?	Yes — Procedures are in place to identify and manage nested correspondent relationships and ensure NVC Fund Bank's controls are not circumvented.
Does the institution apply the SWIFT Know Your Customer's Customer (KYCC) principle?	Yes — KYCC principles are applied for higher-risk correspondent relationships.
Does the institution have a process to review correspondent relationships periodically?	Yes — Correspondent banking relationships are subject to periodic review no less than every two years, or more frequently for higher-risk relationships.

Section 8 — Anti-Bribery & Corruption

Question	Response
Does the institution have an anti-bribery and corruption (ABC) policy?	Yes — An ABC policy is in place covering gifts, entertainment, facilitation payments, and third-party intermediaries.
Does the ABC policy apply to third parties and agents?	Yes — Third-party due diligence requirements extend to agents, introducers, and service providers with client-facing roles.

Section 9 — Financial Crimes Compliance Function

Question	Response
Designated Compliance Officer name and title	Dr. Hashiru OL. Ajadi Muniru, Ph.D., FCSI, DMS, CFA — Chief Compliance & Financial Crimes Officer
Compliance inquiries contact	compliance@nvcfundbank.com
Does the Compliance Officer have direct access to senior management?	Yes — The Compliance Officer reports directly to the Executor and has unfettered access to senior leadership.
Does the institution have a whistleblower / reporting channel?	Yes — A confidential reporting channel is available to all staff and applicable third parties for reporting compliance concerns without fear of retaliation.
Is the compliance function independent from business lines?	Yes — The compliance function operates independently from revenue-generating activities.

Certification

The information provided in this Correspondent Banking Due Diligence Questionnaire is accurate and complete to the best of the knowledge of NVC Fund Bank's Compliance Division. Supporting documentation for any response above is available upon execution of a mutual Non-Disclosure Agreement.

NVC Fund Holding Trust — Compliance Division — March 2026

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Correspondent Banking Due Diligence Questionnaire