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 Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Policy.

Effective Date: 09/09/2025

This policy outlines the mandatory obligations of all PRIDESTATE directors, management, employees, contractors, and partners to prevent and mitigate the risk of the Company’s services being used to facilitate money laundering or the financing of terrorism. The provisions of this policy are legally binding and are designed to ensure strict compliance with the Commonwealth Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime.

1. Policy Objectives.

The primary objectives of this policy are to:

  • Ensure the Company’s full compliance with all relevant AML/CTF legislation.
  • Establish a robust framework for identifying, assessing, and mitigating the risks associated with financial crime.
  • Provide a clear set of guidelines for reporting suspicious activities to the appropriate regulatory body, the Australian Transaction Reports and Analysis Centre (AUSTRAC).
  • Protect the Company’s reputation and integrity from being compromised by illegal financial activities.

2. Legal and Regulatory Framework.

This policy has been developed to ensure the Company’s compliance with the following key legislative instruments:

  • Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). This is the principal piece of legislation governing the Company’s AML/CTF obligations. It mandates the implementation of an AML/CTF program, customer due diligence, and suspicious matter reporting.
  • Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1). These rules provide specific details on how to comply with the obligations set forth in the Act, particularly concerning customer identification and verification procedures.
  • Financial Transaction Reports Act 1988 (Cth). This act is a preceding piece of legislation that remains relevant for certain reporting obligations.

3. Key AML/CTF Obligations.

3.1 Customer Due Diligence (CDD)

Prior to providing any designated service, all personnel, including contractors and partners, must undertake a comprehensive CDD process. This includes, but is not limited to:

  • Identity Verification: Accurately verifying the identity of all clients and, where applicable, the beneficial owners of corporate entities.
  • Risk Assessment: Evaluating the client and transaction to determine the level of money laundering and terrorism financing risk. A high-risk client or transaction requires enhanced due diligence.

3.2 Reporting Obligations

All personnel, including contractors and partners, are legally obligated to report suspicious activities. This includes:

  • Suspicious Matter Reports (SMRs). Any transaction or activity that is considered suspicious must be reported to AUSTRAC immediately, regardless of the amount. This includes activities inconsistent with a client’s known business or personal activities.
  • Threshold Transaction Reports (TTRs): Any cash transaction of AU$10,000 or more must be reported to AUSTRAC within 10 business days.

3.3 Record Keeping

Records of all CDD processes, transactions, and reports submitted to AUSTRAC must be retained for a minimum of seven (7) years. These records are critical for compliance and are subject to audit by AUSTRAC.

3.4 Training and Awareness

All personnel, including contractors and partners, must complete mandatory AML/CTF training upon commencement and at least annually thereafter. The training will cover the risks, the Company’s obligations, and the procedures for compliance.

4. Application to Contractors and Partners.

This policy extends to all individuals and entities acting as contractors or partners of PRIDESTATE. Your obligations are as follows:

  • Compliance: You are required to fully comply with all aspects of this policy as if you were an employee of the Company.
  • Reporting: You must report any suspicious activity or transaction directly to the Company’s designated Compliance Officer in a timely manner. You are not to report directly to AUSTRAC unless explicitly instructed to do so by the Compliance Officer.
  • Confidentiality: All information related to suspicious activity and reporting is to be handled with the utmost confidentiality.

5. Roles and Responsibilities.

  • Board of Directors: The Board is responsible for the overall oversight of the AML/CTF program, ensuring it is comprehensive, effective, and compliant with all legal requirements.
  • AML/CTF Compliance Officer: This designated individual is responsible for the day-to-day management and implementation of the program, including training, reporting, and responding to inquiries from AUSTRAC.
  • All Personnel, Contractors, and Partners: Each individual is personally responsible for adhering to this policy and for reporting any and all suspicious activity.

6. Non-Compliance.

Failure to adhere to the provisions of this policy is considered a serious breach of professional and legal duties. Such non-compliance may result in disciplinary action, including termination of employment or contract, and may also expose the individual to civil or criminal penalties under the AML/CTF Act.

7. Policy Review.

This policy shall be reviewed on an annual basis or as required by a material change in legislation or business operations.