1. POLICY STATEMENT

Ascentix Swiss SA (“Ascentix” or “the Company”) is committed to full compliance with the Anti-Money Laundering and Countering the Financing of Terrorism (“AML/CFT”) laws and regulations of Switzerland. This policy outlines the internal controls, procedures, and training measures implemented to prevent and detect money laundering and the financing of terrorism.
Ascentix adopts a zero-tolerance approach to any form of money laundering, terrorist financing, or other financial crime and ensures that its business activities are conducted with integrity, transparency, and in accordance with applicable laws.

2. LEGAL & REGULATORY FRAMEWORK

This Policy is guided by the following Swiss legislation and guidance:
Swiss Anti-Money Laundering Act (AMLA)
Swiss Criminal Code (SCC), particularly Articles 305bis and 260ter
Anti-Money Laundering Ordinance (AMLO-FINMA)
Financial Market Supervision Act (FINMASA)
Guidelines issued by the Swiss Financial Market Supervisory Authority (FINMA)
Applicable international standards including the FATF Recommendations

3. SCOPE OF APPLICATION THIS POLICY APPLIES TO

All directors, officers, employees, consultants, and contractors of Ascentix
All business relationships, clients, and counterparties
All products and services offered by Ascentix

4. DEFINITIONS

Money Laundering: The process by which the proceeds of crime are disguised to give the appearance of legitimacy
Terrorist Financing: The collection or provision of funds for terrorist acts
Customer Due Diligence (CDD): The process of identifying and verifying a customer’s identity
Politically Exposed Person (PEP): An individual with prominent public functions and their immediate family and close associates.

5. RISK-BASED APPROACH (RGA)

Ascentix adopts a risk-based approach to AML/CFT compliance by:
Assessing the risk of money laundering and terrorist financing posed by each client, product, and service
Applying proportionate CDD measures based on the risk level
Implementing Enhanced Due Diligence (EDD) for high-risk clients and transactions, including PEPs and those in high-risk jurisdictions.

6. CUSTOMER DUE DILIGENCE (CDO)

6.1 Standard CDD
Before establishing a business relationship, Ascentix shall:
Identify and verify the client’s identity
Identify beneficial owners
Understand the nature and purpose of the business relationship
6.2 Enhanced Due Diligence (EDD)
EDD is applied when:
The client is a PEP
The client is from a high-risk jurisdiction
The transaction is complex or unusually large with no apparent economic rationale
6.3 Simplified Due Diligence (SDD)
May be applied in low-risk cases with documented justification, in accordance with FINMA guidance.

7. ONGOING MONITORSKE

All business relationships are subject to continuous monitoring, including:
Scrutiny of transactions for consistency with the client’s profile
Periodic review of client files
Updating CDD information when necessary.

8. SUSPICIOUS ACTINITY REPORTING (SAR)

Employees must report any suspicion of money laundering or terrorist financing to the Nominated Officer / Money Laundering Reporting Officer (MLRO) immediately.
Reports must be submitted in writing
The MLRO assesses the suspicion and, if appropriate, submits a Suspicious Activity Report (SAR) to the Money Laundering Reporting Office Switzerland (MROS)

9. RECORD KEEPING

Records of CDD, transactions, and internal reports are retained for at least 10 years from the end of the business relationship or the date of the transaction, as required by Swiss law.

10. TRAINING AND AWARENESS

All staff receive AML/CFT training tailored to their role, including:
Recognizing suspicious activity
Understanding legal obligations under the Swiss AML regime
Internal reporting procedures.

11. INDEPENDENT AUDIT AND REVIEW

Ascentix will periodically review and update its AML framework. An independent audit or compliance review may be conducted to assess the program’s effectiveness.

12. ROLES AND RESPONSIBILITIES

Board of Directors: Oversees AML governance and ensures effective risk management
MLRO: Ensures AML compliance, evaluates internal reports, and files SARs with MROS
All Employees: Must comply with this policy and report any suspicions promptly.

13. SANCTIONS COMPLIANCE

Ascentix screens clients and transactions against sanctions lists, including:
Swiss SECO (State Secretariat for Economic Affairs)
United Nations Security Council
European Union
US OFAC (where applicable)
Business will not be conducted with any sanctioned individuals or entities.

14. TIL POLICY REVIEW

This policy shall be reviewed annually or upon significant changes in Swiss legislation or the operations of Ascentix Swiss SA.
Approved by the Board of Directors