Anti-Money Laundering Policy

As a company, Elites Funding ("the Company," "we," "our," or "us") is committed to maintaining high standards of compliance with applicable anti-money laundering ("AML") and counter-terrorist financing ("CTF") requirements. This policy is intended to help ensure that our management, staff, contractors, and relevant service providers comply with applicable AML laws and that our products, services, systems, and payment flows are not misused for money laundering, terrorist financing, fraud, sanctions evasion, or other unlawful purposes.

This AML Policy outlines the responsibilities of Elites Funding and its relevant stakeholders in maintaining effective controls against money laundering, terrorist financing, fraud, and related financial crime risks.

Elites Funding will continuously review and, where necessary, update its AML procedures, monitoring systems, controls, and internal standards to reflect operational needs, legal requirements, and evolving best practices.

All relevant personnel are expected to comply with this policy. This includes, where applicable, client screening, identity verification, Know Your Customer ("KYC") procedures, beneficial ownership checks, sanctions screening, embargo policies, suspicious activity reporting, record retention, and employee training.

This policy establishes the minimum AML and CTF standards expected across the Elites Funding platform and associated operations.

Its objectives are to:

• Prevent the misuse of the Company, its personnel, systems, payment channels, and clients for money laundering, terrorist financing, fraud, sanctions evasion, or other financial crime
• Provide a practical framework for the identification, assessment, and management of AML-related risks
• Support compliance with applicable legal, regulatory, and internal obligations
• Promote a culture of vigilance, accountability, and risk awareness throughout the organization

This policy applies to Elites Funding, its management, employees, contractors, and, where relevant, third-party service providers involved in the delivery, administration, support, or oversight of our services.

Where local law imposes stricter requirements than those described in this policy, the stricter standard shall apply. Where any conflict arises between this policy and mandatory legal or regulatory requirements, Elites Funding reserves the right to apply the stricter, more risk-averse, or otherwise legally appropriate standard.

If minimum AML requirements cannot be effectively applied in a particular jurisdiction, or if a jurisdiction presents unacceptable regulatory, sanctions, fraud, or AML risk, the Company may decline to establish, continue, or renew any business relationship connected to that jurisdiction.

Money laundering generally refers to conduct intended to conceal, disguise, transfer, legitimize, or otherwise obscure the unlawful origin of funds or assets derived from criminal activity. It may also include conduct linked to terrorist financing, fraud proceeds, sanctions evasion, corruption, organized crime, tax evasion, or other unlawful acts.

Money laundering commonly includes three stages:

1. Placement: introducing illicit funds or assets into financial or commercial systems
2. Layering: moving, restructuring, or disguising funds through complex or repeated transactions to obscure their origin
3. Integration: reintroducing laundered proceeds into the economy or financial system in a form that appears legitimate

These stages may overlap, repeat, or appear in different forms depending on the facts and circumstances. Businesses may be exposed to AML risks at any point in this process.

Elites Funding applies identity verification and client identification procedures designed to support compliance with applicable AML, KYC, fraud prevention, and payout-control requirements.

Prior to granting access to certain services, funded account benefits, payout capabilities, or contractor-related payment arrangements, the Company may require satisfactory documentary evidence of identity and, where relevant, address or other supporting information.

Required documentation may include, without limitation:

• A valid passport, national identity card, or driver’s license
• Proof of current residential address, such as a utility bill, bank statement, or government correspondence dated within an acceptable period
• Any other documentation reasonably required for tax, compliance, fraud prevention, payout verification, or regulatory purposes

The Company reserves the right to request additional information, perform enhanced verification, reject insufficient documentation, or refuse access to services where identity, ownership, source of funds, or legitimacy cannot be satisfactorily established.

Elites Funding does not knowingly establish or maintain relationships with persons or entities that present unacceptable AML, sanctions, fraud, or terrorist financing risk.

The Company may reject, suspend, or terminate any client, transaction, payout request, or business relationship where risk indicators, verification concerns, or compliance issues arise.

Enhanced due diligence may be applied to clients or transactions assessed as higher risk.

Elites Funding does not provide services to residents of jurisdictions subject to applicable OFAC sanctions or jurisdictions appearing on the FATF blacklist, and may decline service to any jurisdiction or person at its discretion for compliance, sanctions, fraud, or risk-management reasons.

Any suspicious activity, attempted misuse of services, irregular payment behavior, unusual account activity, inconsistent identification information, structuring behavior, sanctions concerns, or indicators of fraud, money laundering, or terrorist financing must be escalated internally without delay.

Suspicious activity may include, without limitation, attempts to avoid identity checks, use of false or misleading information, unusual payment patterns, third-party payment inconsistencies, unexplained use of multiple identities or accounts, or any conduct inconsistent with the stated profile of the user.

Where deemed appropriate, Elites Funding may suspend services, delay payouts, request additional documentation, terminate accounts, refuse transactions, or make reports to appropriate authorities, payment providers, or compliance partners.

Elites Funding maintains records relating to client identification, verification activity, transactions, account activity, internal reviews, compliance decisions, and suspicious activity reporting for such period as may be required by law, regulation, internal policy, operational necessity, fraud prevention needs, or dispute resolution requirements.

Such records may be made available to competent authorities, courts, regulators, law enforcement agencies, payment providers, or other authorized parties where legally required or where necessary to protect the Company’s legitimate interests.

Relevant employees and personnel may receive AML and compliance-related guidance or training appropriate to their role, including how to identify suspicious activity, escalate concerns, and support the Company’s fraud prevention, sanctions, KYC, and AML obligations.

Training and internal guidance may be updated periodically to reflect changes in legal requirements, operational practices, risk patterns, or emerging financial crime techniques.

For questions regarding this AML Policy, please contact us at [email protected].