Anti-Money Laundering Policy

Introduction

Money laundering poses a significant threat to the stability and integrity of the global financial system, undermining trust and facilitating illicit activities such as terrorism, drug trafficking and organised crime. As such, Cardinals FZ-LLC recognises the importance of taking proactive measures to combat money laundering and safeguard the integrity of our operations. This Anti-Money Laundering Policy serves as a cornerstone of our commitment to maintaining transparency, accountability and ethical business practices.

Purpose

The purpose of this policy is to establish guidelines and procedures to:

• identify and assess the risks of money laundering associated with our business operations;
• implement appropriate controls and measures to prevent and detect money laundering activities;
• ensure compliance with relevant anti-money laundering laws and regulations;
• provide training and awareness to employees to recognise and report suspicious activities.

Legal and regulatory framework

Cardinals FZ-LLC is committed to complying with all applicable laws and regulations related to anti-money laundering, in particular Federal Decree-Law No. 20 of 2018 on AML/CFT, Federal Decree-Law No. 7 of 2024, along with UAE Cabinet Decision No. 10 of 2019 (Executive Regulations).

Ultimate Beneficial Ownership (UBO) records

Cardinals FZ-LLC establishes internal procedures for collecting, verifying and maintaining UBO information, including periodic reviews and disclosure in accordance with RAKEZ and federal requirements (in particular Cabinet Decision 58 of 2020), and discloses such records to relevant authorities when requested.

Cardinals FZ-LLC stores and updates data about each beneficial owner in the register of beneficial owners, and registers any changes within 15 days of receiving information about such changes. The following data is stored:

• full name, nationality, date and place of birth;
• residential address or the address to which notices shall be sent;
• number of passport or identity card, the country of issuance, date of issuance and expiry;
• basis and date on which the person became a Beneficial Owner of the Legal Person;
• date on which the person ceased to be a Beneficial Owner of the Legal Person.

Risk Assessment

Cardinals FZ-LLC conducts regular risk assessments to identify and evaluate the potential risks of money laundering associated with our business activities. This assessment takes into account factors such as:

• the nature of our products and services;
• geographic locations of operations;
• customer demographics;
• delivery channels and transaction volumes.

Based on the risk assessment, appropriate controls and measures are implemented to mitigate identified risks effectively. By identifying and prioritising areas of heightened risk, we are better equipped to allocate resources strategically, implement targeted controls and tailor our compliance efforts to mitigate the specific threats posed by money laundering activities.

Customer Due Diligence (CDD)

Cardinals FZ-LLC implements comprehensive Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures in accordance with RAKEZ guidance and applicable UAE federal legislation, maintaining the required minimum standards for customer verification and risk management, including:

• verification of customer identity using reliable, independent and up-to-date documentation (e.g. passports, identification cards, corporate registration documents);
• a risk-based process to identify and assess Politically Exposed Persons (PEPs), including their family members and close associates;
• assessment of exposure to high-risk jurisdictions, including review of relevant sanctions lists, jurisdictions with strategic AML/CFT deficiencies and other credible risk indicators;
• ongoing monitoring of customer relationships and transactions, including periodic updates of customer information, review of changes in risk profiles and detection of unusual or suspicious activity.

Where high-risk indicators are identified, Cardinals FZ-LLC conducts EDD, which includes obtaining additional information, undertaking deeper analysis of the customer and source of funds, and documenting the rationale for establishing or continuing the business relationship. The company maintains clear escalation procedures setting out the steps to be followed when elevated risk is detected, including referral to designated compliance personnel and decision-making regarding enhanced monitoring or termination of the relationship.

Transaction Monitoring

Transaction monitoring is a critical component of Cardinals FZ-LLC's AML framework, enabling the detection and investigation of suspicious activities in real time. Our monitoring systems utilise advanced analytics and rule-based algorithms to identify unusual patterns, trends and anomalies indicative of potential money laundering or terrorist financing activities.

Cardinals FZ-LLC is registered on the UAE Financial Intelligence Unit's (FIU) goAML platform, enabling the submission of Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs) as mandated under UAE AML/CFT legislation. The company maintains a structured internal process for identifying, escalating and reporting suspicious transactions:

• Identification: all transactions are screened against defined thresholds, behavioural patterns and risk indicators. Potentially suspicious activity is flagged for further review.
• Escalation: any alert generated by the monitoring system is referred to the Compliance Officer for assessment. Where warranted, additional information is obtained.
• Reporting: if suspicion remains after internal review, the Compliance Officer submits the appropriate report (STR/SAR) through the goAML platform and ensures that RAKEZ Compliance is notified where required.

Table 1 — Transaction Monitoring Parameters

Parameter	Description
Transaction Amount	Monitoring transactions above a certain threshold for further investigation.
Frequency of Transactions	Identifying unusually frequent transactions by the same customer.
Transaction Patterns	Analysing transaction patterns such as round-figure amounts or repetitive behaviour.

Table 2 — Transaction Monitoring Thresholds

Transaction Type	Threshold Amount	Frequency Threshold
Cash Deposits	AED 100,000.00	1 deposit/day
Wire Transfers	AED 100,000.00	2 transfers/day
High-Risk Countries	Varies based on risk assessment	—
Structured Transactions	AED 100,000.00	2 transactions/week

By continuously monitoring customer transactions and account activities against these parameters and thresholds, Cardinals FZ-LLC promptly identifies and escalates suspicious behaviour. Our reporting framework ensures timely and accurate communication with both the FIU and RAKEZ Compliance, supporting effective regulatory cooperation and upholding the integrity of our AML governance.

Sanctions Screening

Cardinals FZ-LLC conducts sanctions screening in accordance with Cabinet Resolution No. 74 of 2020, which mandates compliance with UN Security Council resolutions and the UAE's domestic terrorism lists. Sanctions screening forms an integral part of our AML/CFT framework and applies to all customers, beneficial owners, transactions and ongoing business relationships.

All customers and relevant parties are regularly screened against the UN Consolidated List, the UAE Local Terrorist List and any other applicable sanctions lists. Transactions are screened on an ongoing basis to ensure that no designated individuals or entities are involved directly or indirectly. Updates to sanctions lists are monitored in real time.

The Compliance Officer is responsible for reviewing alerts, determining whether a match is true or false, and taking the required actions in accordance with UAE law. Where a confirmed match is identified, the company will block or reject the transaction, if required, and promptly escalate the matter to the relevant authorities, including the UAE Financial Intelligence Unit (FIU), the Executive Office for Control & Non-Proliferation (EOCN) and RAKEZ Compliance where applicable.

Reporting and Recordkeeping

Cardinals FZ-LLC maintains comprehensive and accurate records as part of its obligations under UAE AML/CFT legislation and RAKEZ requirements. All documentation related to customer due diligence (CDD), transaction records, internal reviews, suspicious activity reports (SARs) and AML/CFT training is retained for a minimum of five years following the end of the business relationship or the completion of the transaction, whichever is later.

Employees are required to promptly report any suspicious transactions or activities to the designated Compliance Officer, who will assess the information and determine whether further action, including the filing of a SAR, is necessary. These records play a vital role in identifying trends and patterns indicative of potential money laundering or terrorist financing activities.

Training and Awareness

Cardinals FZ-LLC provides regular AML/CFT training and awareness programmes to ensure that all employees clearly understand their responsibilities in preventing, identifying and reporting money laundering and terrorist financing activities. Training covers relevant laws and regulations, internal policies and procedures, recognition of red flags, responsibilities for escalating concerns and proper use of internal reporting channels. Training records are maintained in accordance with statutory retention requirements.

Compliance Monitoring and Review

Cardinals FZ-LLC conducts periodic reviews and audits of its anti-money laundering policies and procedures to ensure they remain effective and up to date. This includes assessing the adequacy of existing controls and measures, identifying areas for improvement and implementing corrective actions as necessary.

AML Compliance Officer

Cardinals FZ-LLC formally designates a Money Laundering Reporting Officer (MLRO), responsible for overseeing the company's compliance with all AML/CFT obligations. The MLRO holds sufficient seniority, independence and authority to carry out their duties and has unrestricted access to relevant records, systems and resources. Responsibilities include, but are not limited to:

• overseeing the implementation and effectiveness of the AML/CFT framework;
• reviewing internal reports of unusual or suspicious activities submitted by employees;
• deciding whether a SAR or STR should be submitted to the UAE FIU via the goAML platform;
• acting as the primary point of contact for regulatory authorities, including RAKEZ Compliance and the FIU;
• ensuring that AML/CFT policies, procedures and controls remain up to date with regulatory changes and evolving risks;
• coordinating and overseeing AML training and awareness programmes;
• ensuring that the company maintains comprehensive AML/CFT records in accordance with legal requirements.

Source of Funds and Source of Wealth

As part of Enhanced Due Diligence (EDD) for high-risk customers — including PEPs, clients from high-risk jurisdictions and customers presenting elevated risk indicators — Cardinals FZ-LLC requires verification of Source of Funds (SoF) and Source of Wealth (SoW). This includes obtaining and reviewing reliable and verifiable documentation, such as bank statements, audited financial statements, business ownership documents, salary certificates or other supporting evidence that clearly establishes the legitimacy of the customer's funds and overall wealth. These procedures are applied before establishing a business relationship and throughout its duration where risk profiles change or new high-risk factors emerge.

Conclusion

Cardinals FZ-LLC recognises that combating money laundering is a collective responsibility that requires ongoing vigilance, collaboration and adaptation to evolving threats. By adhering to the principles outlined in this Anti-Money Laundering Policy and embracing a culture of compliance throughout our organisation, we reaffirm our commitment to upholding the highest standards of integrity, ethics and regulatory compliance.