AML/KYC Policy

ANTI-MONEY LAUNDERING (AML) & KYC POLICY

Effective Date: February 9, 2026

1. Statement of Commitment

Mellon's Company LLC (the "Company"), as a subsidiary of Luxmal Group LLC, is committed to the highest standards of financial integrity and corporate transparency. We operate in strict accordance with the Bank Secrecy Act (BSA), the USA PATRIOT Act, and the recommendations of the Financial Action Task Force (FATF). The Company maintains a zero-tolerance policy regarding money laundering, terrorism financing, and other illicit financial activities.

2. "Know Your Customer" (KYC) Framework

Before entering into any formal consultancy agreement or executing any proprietary "Investment Formula," the Company performs a mandatory Due Diligence process. All prospective partners and clients must provide:

Proof of Identity: Valid government-issued identification for all individual principals.
Corporate Transparency: For legal entities, full disclosure of the Ultimate Beneficial Ownership (UBO) structure, including Certificate of Incorporation and Articles of Association.
Verification of Authority: Documentation confirming that the individual signatory is authorized to bind the entity.

3. Source of Funds (SoF) and Source of Wealth (SoW)

To ensure the legitimacy of our global operations, the Company reserves the right to request:

Detailed declarations regarding the Source of Funds for specific transactions.
Evidence of the Source of Wealth to ensure alignment with the partner's financial profile.
Bank references and historical financial statements where deemed necessary by our Compliance Office.

4. Sanctions Screening and Global Monitoring

Mellon's Company LLC utilizes advanced screening protocols to cross-reference all partners against international sanctions lists, including but not limited to:

OFAC (U.S. Department of the Treasury's Office of Foreign Assets Control).
UN Security Council Consolidated List.
EU and UK Financial Sanctions Lists. The Company will not engage in business with any individual or entity designated on these lists or residing in high-risk jurisdictions as defined by the FATF.

5. Reporting Obligations and Suspicious Activity

In compliance with Delaware and U.S. Federal law, the Company maintains a rigorous monitoring system.

Suspicious Activity Reports (SARs): We reserve the right to report any transaction or communication that appears to have no apparent economic or lawful purpose to the Financial Crimes Enforcement Network (FinCEN).
Confidentiality of Reporting: Pursuant to federal law ("Tipping-Off" rules), the Company is prohibited from notifying any party that a report regarding their activity has been filed.

6. Record Keeping and Data Protection

All documents obtained during the AML/KYC process are stored in a secure, encrypted environment. These records are maintained for a minimum of five (5) years after the termination of the business relationship, in accordance with federal record-keeping requirements.

7. Contact our Compliance Department

For questions regarding our due diligence requirements or to submit compliance documentation, please contact:

Mellon's Company LLC Compliance & Risk Office 1013 Center Road, Suite 403A Wilmington, DE 19805, USA Email: mellons@usa.com