Anti-money laundering policy   As a company, Elites Funding (“The Company,” “We,” “Our,” “Its”) is dedicated to upholding the highest standards of compliance with anti-money laundering (“AML”) regulations. The Company mandates that Its management and employees adhere to and comply with all relevant laws and regulations aimed at combatting money laundering and terrorist financing. Furthermore, the Company ensures that its products and services are not misused for money laundering purposes. This policy serves to outline the individual responsibilities of the Company and its stakeholders in adhering to global anti-money laundering and counter-terrorist financing laws (“AML Laws”). Additionally, it emphasizes the importance of ensuring that any third parties engaged by Elites Funding act in accordance with these laws. Elites Funding will continuously evaluate its anti-money laundering strategies, goals, and objectives and maintain an effective Anti-Money Laundering Policy that aligns with the best practices for a global financial company. All employees are responsible for adhering to the Company’s Anti-Money Laundering Policy. This policy encompasses client screening and monitoring requirements, “Know Your Customer” (“KYC”) policies, including the establishment of beneficial owners’ identities, embargo policies, record-keeping requirements, reporting suspicious activities in compliance with applicable laws, and employee training. The objective of this policy is to provide employees, contractors, and other third parties acting on behalf of the Company with a clear understanding of potential breaches of AML Laws and to support them in making informed decisions consistent with our corporate stance as outlined in this policy.   Scope

• Objectives

This policy sets forth the minimum requirements based on applicable legal and regulatory obligations and applies to the entire organization of Elites Funding. These requirements are in place to prevent the misuse of the Company, its employees, and clients for money laundering, terrorist financing, or any other financial crimes. This policy establishes a comprehensive framework for combating money laundering and terrorist financing.

• Applicability

Elites Funding is obliged to ensure that its subordinated enterprises, branches, subsidiaries, and affiliates in the Gibraltar and other jurisdictions fulfill their legal duties as stipulated by the Anti-Money Laundering Act 2006. In cases where local regulations are more stringent than the requirements outlined in this policy, the stricter standard must be applied. If any applicable laws conflict with this policy, the relevant Elites Funding entity must consult with the local legal department to resolve the conflict. If the minimum requirements stated in this policy cannot be applied in a particular country due to legal or non-legal reasons, Elites Funding must ensure that it refrains from initiating or continuing any business relationships or transactions. If business relations already exist in that country, Elites Funding must ensure that the business relationship is terminated, irrespective of other contractual or legal obligations.

• Definition of the Term Money Laundering

Money laundering refers to participating in any transaction that aims to conceal or disguise the nature or origin of funds derived from illegal activities, such as fraud, corruption, organized crime, or terrorism. Predicate offenses for money laundering are defined by local laws. Generally, the money laundering process consists of three stages:

1. 1. Placement: Introducing illegally obtained funds or valuables into financial or non-financial institutions.
   2. Layering: Separating the proceeds of criminal activity from their source through complex financial transactions, creating layers that obscure the audit trail, disguise fund origins, and provide anonymity.
   3. Integration: Reintroducing the laundered proceeds into the economy in a manner that makes them appear legitimate within the financial system.

These stages are dynamic and can overlap. Financial institutions can be exploited at any point in the money laundering process.   Procedure manual

• Client Identification Procedures

As part of Elites Funding’s AML Policy, the Company has implemented robust procedures to ensure the verification of all clients’ identities before granting payout commissions as a contractor. Prior to opening a contractor account for an individual client, Elites Funding requires satisfactory documentary evidence of the client’s name, address, date of birth, and may include, but is not limited to, the following forms of identification:

1. 1. Passport or National ID
   2. Proof of address
   3. Any other relevant documentation as required by the local tax authorities

Prohibited Clients Elites Funding strictly prohibits the opening of accounts or acceptance of funds or securities from any person or entity who poses a risk related to money laundering or terrorist financing. To mitigate this risk, the Company conducts enhanced and well-documented due diligence on prospective clients. High-risk clients are subject to thorough evaluation before any business relationship is established or transactions are conducted on their behalf. Elites Funding does not offer services to any clients who are residents of any of the OFAC sanctioned countries or FATF blacklisted countries.