Know Your Customer

Blue Whale Holdings is committed to complying with all relevant AML and funding of terrorism regulations. The following policy is derived from the general principles, laws, regulations, and directives for combating money laundering.

We believe that compliance with AML and CFT regulations is essential for the integrity of financial systems and to prevent our company from being used, intentionally or unintentionally, by criminal elements.

We have implemented Know-Your-Customer (KYC) programs as a critical element for service, risk management, and control procedures. We are obliged to establish the identity of our clients and monitor account activity to identify transactions that do not align with the expected behavior for that client or type of account. The program also includes record-keeping requirements, the reporting of suspicious activity, and AML training.

// What is Money Laundering?

Money laundering involves handling or possessing criminal property, including the proceeds of one's own crime and facilitating the handling or transfer of criminal property for another person. This can include proceeds from fraud, bribery, or corruption.

A simplified view of an effective money laundering operation involves three stages:

• Placement of physical cash into a bank account.
• Layering: Multiple transactions to confuse the audit trail and separate the money from its origin.
• Integration: Laundered proceeds are integrated into the legitimate economy, appearing as normal business funds.

For the purpose of this policy, money laundering also includes activities related to terrorist financing.

// Know-Your-Customer

We ask clients several questions during the application stage to understand them and ensure that the applicant is not a victim of financial crime. Documentation is collected to verify the provided information, which may be verified electronically.

// Customer Acceptance

We maintain clear customer acceptance policies, assessing factors like customer background, country of origin, and risk indicators before accepting a potential client.

// Controls

Internal controls include the non-acceptance of cash, third-party deposits, and redemptions. We do not accept customers from restricted or sanctioned countries, U.S. citizens, anonymous accounts, or maintain relationships with shell banks.

// Customer Identification

We obtain necessary information to establish the identity of each new customer and the intended nature of the business relationship. Customer identification includes personal, corporate, and financial information.

// On-Going Monitoring and Reporting

Continuous monitoring of accounts and transactions is crucial. We identify unusual or suspicious patterns of activity and report suspicious transactions as required by law.

// Training and Regular Audits

Employees undergo regular training to stay informed about KYC procedures and new developments. We also conduct regular audits to ensure compliance with regulations.

// Record Keeping

Customer information is retained for at least five years after a transaction or account closure. We ensure all records are readily available to authorities if needed.

// Additional Information Notice

Regulations require continuous monitoring of business relationships. We may ask customers to provide additional documents or information if needed.