AML & KYC Policy

It is the policy of Hezilex (hereinafter referred to as the “Company”) to prohibit and actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. The Company requires its officers, employees and affiliates to adhere to these standards in preventing the use of its products and services for money laundering purposes.

For the purposes of this policy, money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets.

Generally, money laundering occurs in three stages.

Placement
Cash generated from criminal activities first enters the financial system. The funds may be converted into financial instruments such as money orders or traveler’s checks or deposited into accounts at financial institutions.

Layering
Funds are transferred or moved between accounts or financial institutions to further distance the funds from their criminal origin.

Integration
The funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal or legitimate business activities.

Terrorist financing may not involve the proceeds of criminal conduct but instead may involve attempts to conceal the origin or intended use of funds that will later be used for criminal purposes.

Regulatory Compliance

Each employee of the Company whose duties are associated with the provision of products and services and who directly or indirectly interacts with the Company’s clients is expected to understand the requirements of applicable laws and regulations that affect their responsibilities.

It is the responsibility of each employee to carry out their duties in a manner that complies with the relevant laws and regulations.

Applicable laws and regulations include, but are not limited to:

• Customer Due Diligence for Banks (2001)
• General Guide to Account Opening and Customer Identification (2003) issued by the Basel Committee on Banking Supervision
• FATF Forty + Nine Recommendations for Money Laundering
• USA Patriot Act (2001)
• Prevention and Suppression of Money Laundering Activities Law (1996)

AML Compliance Program

To ensure that this policy is properly implemented, the management of the Company maintains an ongoing compliance program designed to ensure adherence to applicable laws and regulations and to prevent money laundering.

This program coordinates regulatory requirements across the organization within a consolidated framework to effectively manage the risk of exposure to money laundering and terrorist financing across all business units, functions and legal entities.

Each affiliate of the Company is required to comply with this AML and KYC policy.

Record Keeping

All identification documents and service records shall be retained for the minimum period required by applicable local laws and regulations.

Employee Training

All new employees are required to complete anti-money laundering training as part of the mandatory onboarding process.

Employees whose responsibilities involve AML and KYC procedures must complete annual AML and KYC training programs.

Additional specialized training may also be required for employees who are directly responsible for AML and KYC compliance tasks.