Anti-Money Laundering (AML) Policy

1. PURPOSE AND SCOPE

This Anti-Money Laundering (AML) Policy outlines WE GOLDEN Pty Ltd’s internal procedures and controls designed to detect, prevent, and report money laundering, terrorist financing, and other illicit financial activities.

WE GOLDEN Pty Ltd complies with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and follows recommendations by the Financial Action Task Force (FATF).

This policy is applicable to all WE GOLDEN Pty Ltd employees, contractors, directors, and relevant business partners.

2. AML FRAMEWORK OVERVIEW

• Compliance Standards:

WE GOLDEN Pty Ltd adheres to PCMLTFA, FINTRAC* regulatory guidance, and FATF standards.

• Risk-Based Approach (RBA):

Risk assessments are conducted to classify customers, services, and geographical exposure into low, medium, or high risk tiers.

3. CUSTOMER DUE DILIGENCE (CDD)

• KYC Requirements:

All customers must provide a legal name, valid identification documents, and disclose source of funds when applicable.

• Enhanced Due Diligence (EDD):

Applied to high-risk individuals, business entities, or jurisdictions with elevated financial crime risk.

• Ongoing Monitoring:

WE GOLDEN Pty Ltd continuously monitors all accounts to identify and assess suspicious behavior or anomalies.

4. TRANSACTION MONITORING

WE GOLDEN Pty Ltd monitors transactional behavior for signs of:

• Unusual volume or velocity.

• Structuring activity (e.g. splitting transactions).

• Inconsistencies with a user’s expected profile.

Any such transactions may be flagged for internal review.

5. REPORTING OBLIGATIONS

• Suspicious Transaction Reporting (STR):

WE GOLDEN Pty Ltd reports to FINTRAC when reasonable suspicion arises regarding any transaction or customer behavior.

• Record Keeping:

All customer due diligence (CDD) records and transaction history will be securely stored for a minimum of five (5) years, in accordance with legal obligations.

6. INTERNAL GOVERNANCE

• AML Compliance Officer:

A designated AML Officer is responsible for implementing, maintaining, and enforcing this policy.

• Training Program:

All staff members are required to complete AML training upon onboarding and annually thereafter.

• Internal Audits:

Regular compliance audits are performed to evaluate the effectiveness of AML controls.

7. POLICY REVIEW

This AML Policy will be reviewed:

• Annually, or.

• Whenever there is a material change in laws, regulations, or business operations that impact AML compliance.

For questions regarding this policy, please contact: ceo@wecopyfintech.com.

* FINTRAC: Financial Transactions and Reports Analysis Centre of Canada.