AML Policy

1. Introduction and Commitment

Meridian Capital Group S.A. ("Meridian Capital") maintains a robust Anti-Money Laundering and Counter-Terrorist Financing ("AML/CTF") compliance program in accordance with applicable international standards, including the Financial Action Task Force (FATF) recommendations, the Swiss Anti-Money Laundering Act (AMLA), and other relevant regulatory frameworks.

We are committed to ensuring that our platform is not used as a vehicle for money laundering, terrorist financing, fraud, or any other financial crime. This commitment extends to all employees, contractors, agents, and users of our platform.

2. Definition of Money Laundering

Money laundering is the process by which the proceeds of criminal activity are disguised to conceal their illicit origins. This typically involves three stages:

• Placement: Introducing illegal funds into the financial system
• Layering: Conducting complex financial transactions to obscure the trail
• Integration: Reintroducing laundered funds into the legitimate economy

Terrorist financing involves providing financial support for terrorist activities, regardless of whether the funds originate from legitimate or criminal sources.

3. Know Your Customer (KYC) Program

3.1 Customer Identification

All users of the Meridian Capital platform are required to complete our identity verification process. Our KYC program includes:

• Collection of full legal name, date of birth, and country of residence
• Verification of government-issued photo identification documents
• Biometric verification through selfie with identification document
• Ongoing monitoring of account activity for suspicious patterns
• Enhanced due diligence for high-risk customers and transactions

3.2 Acceptable Identification Documents

We accept the following forms of government-issued identification:

• Valid national passport
• Government-issued national identity card
• Valid driver's licence (where accepted as primary ID)
• Residence permit issued by competent authority

3.3 Enhanced Due Diligence

Meridian Capital applies enhanced due diligence measures to customers who present higher AML/CTF risks, including Politically Exposed Persons (PEPs), customers from high-risk jurisdictions, customers with complex ownership structures, and customers conducting unusually large or frequent transactions.

4. Transaction Monitoring

We implement comprehensive transaction monitoring systems to detect suspicious activity, including:

• Automated screening of all transactions against sanctions lists and watchlists
• Real-time monitoring of transaction patterns and anomalies
• Review of large transactions exceeding defined thresholds
• Analysis of rapid succession of deposits and withdrawals
• Detection of structuring and smurfing activities
• Monitoring of geographic risk factors and IP addresses

5. Suspicious Activity Reporting

Meridian Capital maintains procedures for identifying and reporting suspicious activity in accordance with applicable laws. When suspicious activity is identified, our compliance team will:

• Document all relevant information and evidence
• File Suspicious Activity Reports (SARs) with relevant authorities as required
• Freeze affected accounts pending investigation where appropriate
• Cooperate fully with law enforcement and regulatory investigations
• Maintain strict confidentiality regarding ongoing investigations (tipping-off prohibition)

6. Sanctions Compliance

Meridian Capital screens all customers and transactions against applicable sanctions lists, including those maintained by:

• United Nations Security Council (UNSC)
• European Union (EU) consolidated sanctions list
• United States Office of Foreign Assets Control (OFAC)
• UK Office of Financial Sanctions Implementation (OFSI)
• Swiss State Secretariat for Economic Affairs (SECO)

We will not conduct business with individuals, entities, or jurisdictions subject to applicable sanctions. Any accounts found to be in violation of our sanctions policy will be immediately frozen and reported to relevant authorities.

7. Prohibited Activities and Jurisdictions

The following activities are strictly prohibited on our platform:

• Depositing funds derived from criminal activity
• Using our platform to transfer or conceal proceeds of crime
• Financing or supporting terrorist organisations or activities
• Evading taxes or other financial obligations
• Violating applicable sanctions or export controls
• Using our platform from sanctioned jurisdictions

8. Record Keeping

Meridian Capital maintains comprehensive records of all customer identification information, transaction records, and AML/CTF compliance activities for a minimum period of five years, or longer where required by applicable law. These records are maintained in a manner that enables us to reconstruct individual transactions and identify customers upon request by competent authorities.

9. Employee Training and Awareness

All Meridian Capital personnel receive regular training on AML/CTF obligations, including how to identify suspicious activity, reporting procedures, and the legal consequences of non-compliance. Our compliance program is reviewed and updated regularly to reflect changes in applicable laws, regulations, and best practices.

10. Consequences of AML Policy Violations

Violations of this AML Policy may result in:

• Immediate suspension or termination of your account
• Freezing of account balances pending investigation
• Reporting to relevant law enforcement and regulatory authorities
• Forfeiture of funds identified as proceeds of crime
• Civil and criminal liability under applicable laws

11. Contact Our Compliance Team

If you have questions about our AML policy or wish to report suspicious activity, please contact our compliance team:

• Email: compliance@meridiancapital.finance
• Support: support@meridiancapital.finance
• Address: Meridian Capital Group S.A., Geneva, Switzerland