Nexus International is dedicated to preventing financial crime by implementing measures to detect and deter money laundering, terrorist financing, and other illegal activities.

Our policy aims to prevent and deter the use of Nexus International for illegal money laundering activities. For our staff to effectively implement this policy, they must understand its background and how it functions within our daily operations. The success of our policy relies on the vigilance of everyone involved.

To ensure these policies are effectively implemented, Nexus International and its entire staff must be:

• Educated about the legal and regulatory frameworks, as well as the severe legal and regulatory consequences of inadvertently aiding financial crime, in every jurisdiction where we operate.
• Vigilant regarding the practical methods criminals use to commit financial crimes.
• Prompt in reporting any suspicious activities to Nexus International management.

The Union of the Comoros is a member of the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG). ESAAMLG's purpose is to combat money laundering by applying the guidelines established by the Financial Action Task Force (FATF).

FATF is an international organization focused on developing and promoting strategies to prevent money laundering and terrorist financing on both national and global levels.

This initiative includes collaborating with other international organizations dedicated to fighting money laundering, analyzing emerging regional trends, enhancing institutional and human resource capacities to tackle these issues, and coordinating technical assistance as needed. ESAAMLG allows for regional considerations to be integrated into the enforcement of anti-money laundering measures.

Members of ESAAMLG engage in a self-assessment process to measure their progress in implementing the FATF's Forty Recommendations.

The Union of the Comoros is an observer member of the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA). It provides support and assistance in addressing issues related to anti-money laundering and combating the financing of terrorism (AML/CFT).

GIABA functions as a body within the Economic Community of West African States (ECOWAS), with the responsibility of aiding in the adoption and execution of Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) standards throughout West Africa. Acting similarly to a FATF-Styled Regional Body (FSRB), GIABA cooperates with member nations to guarantee their compliance with global AML/CFT standards.

Nexus International adheres to a rigorous client approval protocol, exclusively extending services such as guarantee issuance to formally approved legal entities, encompassing both individual and corporate entities. Our verification processes are exhaustive, ensuring the bona fides of potential clients prior to their integration into our operational framework.

While our clientele often enters through intermediary agents, it is incumbent upon Nexus International, not the agents, to meticulously verify the identity and authenticity of prospective clients. Given the heightened risk associated with specific geographic regions such as Africa and India concerning money laundering, we maintain uncompromising documentation standards as delineated in our Compliance Agreement.

Moreover, we conduct comprehensive screenings against international sanctions listings prior to accepting any one-time, non-refundable processing fee related to the compliance procedure. Our vigilance transcends the initial client approval phase. Prior to processing applications for guarantees or similar credit facilities, we require verifiable documentary evidence from clients substantiating the genuine commercial nature of the business or contractual arrangements they aim to secure.

This approach serves as a cornerstone in mitigating the potential misuse of our services, underscoring Nexus International's steadfast commitment to compliance and ethical standards within the finance and technology sectors.

Money laundering is a complex process where individuals involved in illegal activities attempt to conceal the origins of unlawfully obtained funds, often referred to as "dirty" money. Although the methods used for money laundering can vary, they generally involve three main stages:

• Placement : This initial phase involves placing the illicit funds into the legitimate financial system. This could include depositing the money into bank accounts or making investments to integrate it into legal economic activities.
• Layering : During this stage, the money undergoes a series of intricate financial transactions aimed at separating it from its illegal origins. These transactions create a complicated trail, making it difficult to trace the money back to its criminal source.
• Integration: The final step involves reintroducing the laundered funds into circulation through seemingly legitimate channels. At this point, the money appears "clean" or "laundered," making it indistinguishable from funds acquired through legal means.

Nexus International remains steadfast in its commitment to combatting money laundering within the finance and technology sectors.

It's a well-known truth that individuals engaged in illegal activities, such as money laundering, do not overtly present themselves as such. While broad generalizations may not always be helpful, certain red flags indicating a suspicious transaction or illicit activity include:

• Lack of obvious commercial rationale.
• Use of 'front men' or 'front companies' not appearing in the corporate structure.
• Insufficient documentary support for a person or transaction.
• Excessive concern about secrecy, especially regarding the source of funds.

At Nexus International, reporting suspicions is a critical part of our anti-money laundering efforts. Our Money Laundering Reporting Office (MLRO), integrated into senior management, meticulously oversees our anti-money laundering policies. They report directly to Nexus International's Board, ensuring a top-down approach to combating financial crime. It is mandatory for all staff members to promptly report any suspicions of illicit transactions to ESAAMLG through the MLRO.

At Nexus International, meticulous record keeping is paramount to our operations. We maintain thorough records of our client verification processes, ensuring transparency and compliance. All original documentation, whether in paper or electronic format, is retained throughout a client's approval period and for an additional six years thereafter.