**Anti-Money Laundering (AML) Policy for Octalas Group**

**Purpose**

The purpose of this Anti-Money Laundering (AML) Policy is to prevent Octalas Group from being used for money laundering, terrorist financing, and other illicit activities. This policy outlines the company’s commitment to complying with all applicable laws, regulations, and international standards related to AML/CFT (Combating the Financing of Terrorism).

**Scope**

This policy applies to all Octalas Group entities, subsidiaries, and affiliates worldwide, including all employees, contractors, and third-party service providers.

**Responsibilities**

* The Board of Directors is responsible for overseeing the implementation and maintenance of this AML Policy.

* The Compliance Officer is responsible for developing, implementing, and monitoring the AML Program, including training, risk assessments, and reporting.

* All employees are responsible for complying with this policy and reporting any suspicious transactions or activities to the Compliance Officer.

**Customer Due Diligence**

Octalas Group will perform customer due diligence (CDD) on all new and existing customers, including:

* Verifying customer identity through reliable, independent sources

* Assessing customer risk based on factors such as country risk, product risk, and customer type

* Conducting ongoing monitoring of customer activity

**Transaction Monitoring**

Octalas Group will monitor all transactions, including:

* Screening transactions against sanctions lists and watchlists

* Identifying and reporting suspicious transactions to the Compliance Officer

* Maintaining records of all transactions for at least five years

**Reporting and Record-Keeping**

Octalas Group will maintain accurate and detailed records of all AML/CFT-related activities, including:

* Reporting suspicious transactions to the relevant authorities

* Maintaining records of all customer due diligence and ongoing monitoring

* Retaining all records for at least five years

**Training and Awareness**

Octalas Group will provide regular training and awareness programs for all employees on AML/CFT risks, policies, and procedures.

**Independent Review**

Octalas Group will conduct regular independent reviews of its AML Program to ensure its effectiveness and compliance with applicable laws and regulations.

**Amendment and Review**

This policy will be reviewed and updated annually, or as needed, to ensure it remains effective and compliant with changing laws and regulations.

**Confidentiality**

All employees are required to maintain the confidentiality of customer information and AML-related records.

By implementing this AML Policy, Octalas Group demonstrates its commitment to preventing money laundering, terrorist financing, and other illicit activities, and to complying with all applicable laws and regulations.