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1. Purpose

The purpose of this AML/CFT Policy is to outline the commitment of Score Financial Pte. Ltd. to prevent its services from being used for money laundering, terrorist financing, or other criminal activities. This policy ensures compliance with applicable AML/CFT laws, regulations, and best practices.

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2. Scope

This policy applies to all employees, business units, subsidiaries, and third parties acting on behalf of Score Financial Pte. Ltd. It covers all products, services, and transactions, including: a. Customer onboarding and due diligence b. Transaction monitoring and record keeping c. Reporting of suspicious transactions d. Ongoing staff training and compliance monitoring

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3. Policy Statement

Score Financial Pte. Ltd. is committed to: a. Complying with all applicable AML/CFT laws and regulations b. Establishing and maintaining an effective AML/CFT compliance framework c. Identifying and verifying the identity of customers (KYC) d. Detecting, preventing, and reporting suspicious activities e. Cooperating with law enforcement and regulatory authorities f. Maintaining high ethical standards in all business dealings

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4. Roles and Responsibilities

Executive Management a. Provide strategic oversight and ensure adequate resources for AML/CFT compliance b. Approve AML/CFT policies and procedures Compliance Team a. Oversee the implementation of the AML/CFT framework b. Conduct customer due diligence (CDD) reviews and enhanced due diligence (EDD) where necessary c. Monitor transactions and investigate suspicious activities d. File Suspicious Transaction Reports (STRs) with the relevant authorities All Employees a. Comply with AML/CFT requirements in day-to-day operations b. Report suspicious transactions or behaviors c. Complete AML/CFT training as required

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5. Customer Due Diligence (CDD)

Score Financial Pte. Ltd. will apply CDD procedures to: a. Identify and verify customers using reliable, independent documentation b. Understand the nature and purpose of the business relationship c. Conduct ongoing monitoring of transactions Enhanced due diligence (EDD) will be applied to high-risk customers or jurisdictions.

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6. Transaction Monitoring

The company will establish systems and controls to: a. Detect unusual or suspicious transaction patterns b. Flag high-risk behaviors for review c. Escalate concerns to the Compliance Officer for further investigation

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7. Suspicious Transaction Reporting (STR)

All employees are required to promptly report any suspicious activity to the Compliance Officer. The Compliance Officer will: a. Assess the legitimacy of the transaction b. File an STR with the appropriate authority if suspicion is confirmed c. Maintain a confidential record of all reports and actions taken

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8. Record Keeping

Score Financial Pte. Ltd. will maintain AML-related records, including: a. Customer identification and verification documents b. Transaction records and monitoring logs c. STR filings and investigation reports All records will be retained for a minimum of 5 years or as required by law.

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9. Training and Awareness

All employees shall receive: a. AML/CFT training upon hire and annually thereafter b. Training tailored to their specific roles and risk exposure c. Regular updates on regulatory changes and emerging typologies

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10. Compliance and Review

This policy shall be: a. Reviewed at least annually or upon changes in regulations b. Audited periodically to ensure effectiveness c. Updated to reflect evolving threats, risks, and compliance obligations

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11. Exceptions

Any exceptions to this policy must be approved in writing by Executive Management.