Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policy

Effective Date: September 29, 2025

TauKen Group Ltd ("TauKen Group," "we," "us," or "our") is committed to maintaining the highest standards of anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions compliance in line with applicable laws and international standards.

1. Purpose

This Policy sets forth TauKen Group's framework to:

  • Prevent our services from being used for money laundering, terrorist financing, or other illicit activities.
  • Comply with the Financial Action Task Force (FATF) Recommendations, as well as applicable U.S., U.K., and international AML/CTF regulations.
  • Protect the integrity of global financial markets and maintain trust with clients, regulators, and counterparties.
2. Scope

This Policy applies to:

  • All TauKen Group employees, contractors, directors, and affiliates.
  • All clients, counterparties, and third parties engaging with TauKen Group.
  • All business units, products, and services offered by TauKen Group.
3. Regulatory Framework

TauKen Group complies with, but is not limited to, the following frameworks and regulations:

  • USA PATRIOT Act (U.S.)
  • Bank Secrecy Act (BSA, U.S.)
  • EU AML Directives (5AMLD / 6AMLD)
  • UK Proceeds of Crime Act (POCA) & Money Laundering Regulations
  • Financial Action Task Force (FATF) 40 Recommendations
  • Applicable UN, OFAC, and EU sanctions regimes.
4. Know Your Customer (KYC) / Customer Due Diligence (CDD)

TauKen Group implements a risk-based approach to customer verification, including:

  • Individual Clients: Collection and verification of government-issued identification, proof of address, and source of funds.
  • Institutional Clients: Verification of incorporation documents, beneficial ownership structures, authorized signatories, and regulatory licenses.
  • Enhanced Due Diligence (EDD): Applied to high-risk clients, politically exposed persons (PEPs), or clients from high-risk jurisdictions.
5. Ongoing Monitoring
  • Continuous monitoring of client transactions to ensure consistency with known customer profiles.
  • Identification of unusual, complex, or suspicious transactions.
  • Periodic refresh of KYC documentation, depending on client risk profile.
6. Sanctions Compliance
  • All clients and transactions are screened against OFAC, EU, UN, and HM Treasury sanctions lists.
  • TauKen Group will not engage with individuals, entities, or jurisdictions subject to applicable sanctions.
7. Record-Keeping
  • All KYC, CDD, and transaction records are retained for a minimum of five (5) years after the end of the client relationship or transaction, in compliance with applicable law.
  • Records are maintained in secure, encrypted systems accessible only by authorized personnel.
8. Suspicious Activity Reporting
  • Employees are required to escalate red flags to the AML Compliance Officer immediately.
  • TauKen Group will file Suspicious Activity Reports (SARs) or equivalent regulatory filings with the appropriate authorities, without notifying the client (tipping-off strictly prohibited).
9. Training & Awareness

All employees receive annual AML/CTF training covering:

  • Identification of suspicious activity.
  • Reporting obligations.
  • Evolving typologies of financial crime.

Specialized staff receive enhanced training appropriate to their roles.

10. Independent Audit

TauKen Group's AML/CTF program is subject to independent testing and audits to ensure ongoing compliance and effectiveness.

11. Roles & Responsibilities
  • Board of Directors: Overall accountability for AML/CTF compliance.
  • AML Compliance Officer (MLRO): Day-to-day oversight, policy enforcement, and regulatory reporting.
  • Employees: Adherence to policy, reporting suspicious activity, and completing training requirements.
12. Zero-Tolerance Policy

TauKen Group maintains a zero-tolerance policy toward financial crime. Any employee, client, or counterparty found to be in violation of AML/CTF rules will be subject to immediate termination of relationship and, where appropriate, reported to regulatory authorities.

13. Contact

For AML/CTF-related inquiries, please contact:

AML Compliance Officer
TauKen Group Ltd
Email: info@taukengroup.com

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