Anti-Money Laundering Policy

1. Policy Statement

Montrock Ltd is committed to the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. The company operates in full compliance with the Financial Services Commission (FSC) Mauritius AML/CFT requirements and international standards set by the Financial Action Task Force (FATF).

2. Customer Due Diligence (CDD)

All prospective clients are subject to comprehensive CDD procedures before account activation. This includes:

• Verification of identity through government-issued identification documents
• Verification of residential address through utility bills or bank statements
• Determination of source of funds and source of wealth
• Ongoing monitoring of client transactions and activity
• Enhanced Due Diligence (EDD) for higher-risk clients and jurisdictions

3. Risk-Based Approach

Montrock Ltd applies a risk-based approach to AML/CFT compliance. Client risk assessments consider jurisdictional risk, product risk, delivery channel risk, and client-specific factors. Higher-risk relationships are subject to enhanced monitoring and senior management approval.

4. Suspicious Activity Reporting

The company has appointed a Money Laundering Reporting Officer (MLRO) who is responsible for receiving and evaluating internal suspicious activity reports. Where appropriate, reports are submitted to the Mauritius Financial Intelligence Unit (FIU).

5. Record Keeping

All CDD documentation, transaction records, and correspondence are retained for a minimum of seven years following the termination of the business relationship, in accordance with FSC requirements.

6. Staff Training

All employees receive mandatory AML/CFT training upon induction and on an annual basis thereafter. Training covers CDD procedures, suspicious activity identification, reporting obligations, and relevant regulatory developments.

7. Contact

For enquiries relating to this policy, please contact the MLRO at mlro@mon-trock.com.