Huch Anti-Money Laundering (AML) Policy

1. Introduction

Huch, hereafter referred to as “the Company,” is committed to maintaining the highest standards of ethical conduct and regulatory compliance. This Anti-Money Laundering (AML) Policy is designed to prevent and mitigate the risks of the Company being used for money laundering, terrorist financing, or any other financial crime.

2. Purpose and Scope

This policy outlines the measures Huch employs to prevent and detect activities related to money laundering and other illicit financial activities. The policy applies to all employees, agents, contractors, and third parties associated with Huch.

3. Compliance with Applicable Laws

Huch will adhere to all relevant local and international AML laws and regulations. The Company will regularly review and update its policies and procedures to reflect changes in legislation.

4. Customer Due Diligence (CDD) and Know Your Customer (KYC) Procedures

4.1 Customer Identification Program (CIP): Based on the data received by the customers and his partners, Huch will establish and maintain a risk-based CIP to verify the identity of customers. This includes obtaining identification information, such as government-issued IDs, proof of address, and other pertinent details.

4.2 Enhanced Due Diligence (EDD): For customers presenting a higher risk, such as Politically Exposed Persons (PEPs), Huch will conduct enhanced due diligence, including additional verification steps.

4.3 Ongoing Monitoring: The Company will continuously monitor customer transactions and relationships to detect unusual or suspicious activities. This includes periodic reviews of customer information.

5. Reporting and Record Keeping

Huch will promptly report any suspicious activities to the relevant authorities. The Company will maintain records of customer identification and transaction information for the prescribed period as required by law.

6. Training and Awareness

Huch will provide regular training to employees on AML policies and procedures. Staff will be educated on recognizing and reporting suspicious activities.

7. Internal Controls and Procedures

The Company will implement internal controls to ensure the effectiveness of AML procedures. This includes appointing a designated Compliance Officer responsible for AML compliance.

8. Cooperation with Authorities

Huch is committed to cooperating with regulatory authorities in any investigations related to money laundering or terrorist financing. The Company will provide timely and accurate information as required.

9. Risk Assessment

Huch will conduct regular risk assessments to identify and mitigate potential AML risks associated with its products, services, and customer base.

10. Confidentiality

All employees and associated parties are obligated to maintain the confidentiality of AML-related information. Unauthorized disclosure of such information is strictly prohibited.

11. Review and Updates

This AML Policy will be subject to periodic reviews to ensure its continued effectiveness and compliance with evolving AML regulations.