Anti-Money Laundering (AML) Policy of Bellver Markets LLC

1. Purpose
The purpose of this Anti-Money Laundering (AML) Policy is to establish guidelines to prevent, detect, and report
any activity related to money laundering or the financing of terrorism in compliance with international standards.

2. Scope
This policy applies to all employees, officers, and agents of Bellver Markets LLC, including all branches and subsidiaries,
both domestic and international.

3. Definitions
Money Laundering: The process of concealing the origins of illegally obtained money, typically by passing it through a
complex sequence of banking transfers or commercial transactions.
Know Your Customer (KYC): The process of verifying the identity of clients to prevent fraud, money laundering, and terrorist financing.
Suspicious Activity: Any transaction or pattern of activity that raises doubt about its legitimacy or compliance with international AML standards.

4. Legal Framework
Bellver Markets LLC adheres to internationally recognized AML/CFT standards, including the:
- Financial Action Task Force (FATF) Recommendations
- United Nations Security Council sanctions framework
- Wolfsberg Principles on KYC and AML best practices
- Group guidelines for cooperation between financial intelligence units

5. AML Compliance Program

5.1. Risk Assessment
Conduct annual risk assessments to identify potential money laundering risks associated with the organization’s
products, services, customers, and geographic locations.

5.2. Customer Due Diligence (CDD)
Implement KYC procedures for customer identification and verification. Collect and verify the following:
- Full name
- Date of birth (for individuals)
- Address
- Government-issued identification (e.g., passport, national ID)
- Tax identification number or registration (for legal entities)

Exclusion Policy:
Bellver Markets LLC does not onboard or maintain relationships with Citizens, residents or entities of:

• United States of America
• Georgia
• Jurisdictions subject to United Nations sanctions
• Any client refusing to provide sufficient identification or beneficial ownership information

5.3. Ongoing Monitoring
Establish systems to monitor transactions for unusual or suspicious activity.

5.4. Reporting Obligations
Suspicious activity will be escalated to the AML Compliance Officer, who will ensure that such activity is reported to the relevant competent authority in the jurisdiction of operation, in line with international cooperation standards.

5.5. Employee Training
Provide AML and KYC training to all employees upon hiring and at least annually thereafter.

5.6. Record Keeping
Maintain records of customer identification, due diligence, and transactions for at least 5 years after the end of the business relationship.

6. Roles and Responsibilities
AML Compliance Officer:
The AML Compliance Officer is responsible for ensuring compliance with international AML obligations, overseeing training,
and coordinating reporting to competent authorities as necessary.

All Employees:
All employees must comply with the AML Policy, report suspicious activities, and complete mandatory training.

7. Internal Controls
Implement internal controls to mitigate risks, including segregation of duties, regular audits of the AML program,
and compliance checks to ensure adherence to KYC procedures.

8. Enforcement and Disciplinary Action
Violations of this AML Policy may result in disciplinary action, including termination of employment and legal action.

9. Policy Review and Updates
This policy will be reviewed annually and updated as necessary to reflect changes in FATF standards,
UN sanctions lists, and international best practices.

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Bellver Markets LLC
Omar Khizanishvili Street 264 - Gldani District, Tbilisi, Georgia
+44 7737 2135 84
http://bellver.capital