Introduction
The AML and Counter-Terrorist Financing (CTF) Policy is crafted to uphold rigorous
standards in compliance with Swiss and European directives aimed at combating money
laundering and terrorist financing. This policy mandates the establishment of robust systems
and controls to mitigate the risk of our platform being exploited for illicit financial activities.
Engaging in any form of business activity or process transactions that benefit individuals or
entities listed on international sanctions registers is strictly prohibited. Therefore, adherence
to all relevant laws and regulations pertaining to the prevention of money laundering and
terrorist financing, particularly the Swiss Anti-Money Laundering Act (referred to as “AML”),
is integral to the strategic framework and operational ethos of OXCEAN.
OXCEAN maintains stringent and transparent criteria, continually enhancing its operational
procedures to ensure full compliance with applicable AML laws and regulations. We reserve
the right to decline any customer, payment, or business endeavor that contravenes the
principles outlined in our AML policy, irrespective of the requirements stipulated by prevailing
AML laws and regulations.
This commitment underscores our dedication to maintaining the highest integrity and
regulatory compliance standards across all facets of our operations.

Core Objectives
Our primary objectives at OXCEAN encompass:
– Vigilantly combating and thwarting money laundering and terrorist financing activities,
bolstered by robust preventive measures.
– Safeguarding the integrity of our operations from any misuse by individuals engaging
in illegitimate activities.
– Appointment of a senior and autonomous Money Laundering Reporting Officer
(MLRO) tasked with ensuring compliance with relevant legislation, regulations, and
industry directives.
– Implementation and upkeep of a Risk-Based Approach (RBA) to effectively assess
and manage the firm’s exposure to money laundering and terrorist financing risks.
– Adoption of risk-based Customer Due Diligence (CDD), encompassing thorough
identification, verification, and Know Your Customer (KYC) procedures, with
heightened scrutiny for high-risk clients such as Politically Exposed Persons (PEPs).
– Deployment of tailored systems and protocols for continuous monitoring of customer
activities aligned with risk profiles.
– Establishment of comprehensive procedures for internally reporting suspicious
activities and liaising with pertinent law enforcement entities, including the Money
Laundering Reporting Office Switzerland (MROS), as necessitated.
– Maintenance of meticulous records in accordance with regulatory mandates.
– Provision of comprehensive training to all staff on pertinent rules, internal
procedures, and the specific money laundering and terrorist financing risks inherent
to their roles within the company.

These core objectives underscore OXCEANs commitment to robust AML/CFT practices,
ensuring compliance with regulatory frameworks and bolstering our defenses against
financial crime threats.

Commitment
At OXCEAN our commitment is focused on the following principles:
– We only onboard customers after thoroughly verifying their identity and ensuring the
legitimacy of their funding sources.
– We do not establish business relationships, open accounts, or maintain accounts for
anonymous individuals or those using fictitious identities, including anonymous
accounts.
– Every effort is made to ascertain the identity of the customer and the ultimate
beneficiary (Beneficial Owner) of the account, verifying details such as full name,
place of birth, and date of birth using valid, official documents issued by recognized
authorities, alongside information from credible independent sources.
– We employ a risk-based approach, implementing enhanced due diligence as
necessary to manage risks effectively.
– Our systems diligently monitor and flag suspicious transactions and activities for
appropriate reporting.
– Regular and comprehensive AML/CTF training is provided to all employees through
diverse educational methods to enhance awareness.
– We maintain meticulous records tailored to the specific nature and complexity of
each customer's business activities.
These commitments underscore OXCEANs dedication to robust AML and CTF practices,
ensuring compliance with regulatory standards and safeguarding our operations against
financial crime risks.

Customer Due Diligence
OXCEAN is committed to fulfilling its legal obligations by thoroughly identifying and verifying
applicants for business, customers, and beneficial owners. It is imperative to establish the
true identity of individuals and ascertain if they are acting on behalf of others. This process
includes determining the purpose and intended nature of the business relationship, which is
continuously monitored.
Our Customer Due Diligence (CDD) measures are meticulously designed and implemented
across all levels of our organization. These measures assist in assessing each customer's
risk profile and provide insights into their business activities. Any transactions that deviate
from the expected business profile undergo thorough scrutiny to detect potential money
laundering or terrorism financing activities. Prompt reporting to relevant authorities is
ensured whenever necessary information is identified.
In essence, OXCEANs Due Diligence policies are structured to achieve the following
objectives:
– Verification and identification of applicants for business.
– Identification and verification of beneficial owners, where applicable.

– Verify that individuals are not acting as principals in their applications.
– Gathering comprehensive information on the purpose and nature of business
relationships.
– Continuous monitoring of business relationships.
– Establishment of the source of wealth and funds.
– Implementation and enforcement of a robust Customer Acceptance Policy to uphold
compliance standards.
OXCEAN strictly prohibits the maintenance of anonymous or fictitious accounts to uphold
transparency and regulatory compliance.
These measures underscore our commitment to maintaining the highest integrity and
regulatory compliance standards in all our operations.

Prohibited Activities
OXCEAN maintains a stringent stance against engaging with customers involved in activities
that pose significant risks under AML and CTF regulations:
– Deliberate or negligent violations of laws, regulations, or policies pertaining to money
laundering and terrorist financing.
– Repeated accidental breaches of AML laws.
– Misuse of accounts for purposes of money laundering, terrorism financing, or other
fraudulent activities.
– Participation in activities that could be construed as tax evasion.
– Failure to provide adequate information or documentation to demonstrate compliance
with OXCEANs AML policies.
Moreover, OXCEAN refrains from conducting business with customers or transactions
originating from jurisdictions identified as high-risk third countries. These jurisdictions are
identified based on deficiencies in their anti-money laundering frameworks as outlined by the
European Commission and the FATF.

Compliance with Sanctions
OXCEAN adheres strictly to regulatory sanctions, avoiding the establishment or
maintenance of relationships with natural persons or legal entities designated on the
following sanctions lists:
– Swiss Federal Council Sanctions List.
– United Nations Security Council Sanctions List (UN).
– Consolidated List of European Union Financial Sanctions (EU).
– Sanctions administered by the United States Office of Foreign Assets Control
(OFAC), including the List of Specially Designated Nationals and Blocked Persons.

Additionally, OXCEAN exercises heightened vigilance concerning entities from countries
listed as noncooperative by the Financial Action Task Force (FATF), ensuring stringent
adherence to regulations governing monetary operations involving such entities.
These measures underscore OXCEAN commitment to robust AML and CTF compliance,
safeguarding against financial crime and preserving the integrity of our operations.

Monitoring for Suspicious Activity
OXCEANs AML policy encompasses rigorous due diligence on customers and beneficial
owners, complemented by ongoing monitoring and reporting protocols. Periodically, we may
require detailed information on transactions conducted through our customers' accounts and
the involved parties. Should a customer fail to provide adequate or timely responses to these
requests, OXCEAN retains the right to decline associated payments in accordance with the
mandates of applicable AML laws and regulations.
This proactive approach ensures that OXCEAN remains vigilant against potential risks of
money laundering and illicit financial activities, reinforcing our commitment to upholding
regulatory compliance and safeguarding the integrity of our operations.