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Xpress Money Services Limited United Kingdom Anti-money Laundering & Combating Terrorism Financing Policy And Procedures Version 2.5

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Contents INTRODUCTION 2 SECTION I - GENERAL POLICY General Statements on “Money Laundering” 4 XM Anti-Money laundering policies 5 The XM AML&CTF Program 6 Risk Assessment & Mitigation 7 SECTION II - AML/CTF POLICY/ PROCEDURES FOR UK OPERATIONS Appointment of Compliance Officer/s 13 Customer Due Diligence & on-going monitoring of transactions 14 - What is customer due diligence? 14 - Non Compliance with customer due diligence - Identifying Beneficial Owner - Enchanced Due Diligence - Nature & Purpose of Business Relationship - Customer Identification - Documentary Evidence - Electronic Evidence - On-going Monitoring - Other High Risk Situations Anti-Money Laundering Training Program for Agents Retention of Records Identifying and Reporting of Suspicious Activity - General Legal & Regulatory Obligations - Internal Reporting Procedures - Consent to a Transaction - Tipping-off Offences - Suspicion Indicators Supervision & Penalty for non-compliance Regular Review of Agents Anti-Money Laundering Program Appendix I - Summary of XM Money Transfer Requirement Appendix II - XM Acceptable Form of Identity Appendix III - Suuspicios Transaction Report Form Appendix IV - Source of Fund Declaration form Appendix V - Documentation Checklist for Agents Application

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Introduction To: All our Esteemed Agents We are glad to come out with a comprehensive “Xpress Money Anti-Money Laundering & Combating Terrorist Financing Policy & Procedure” (AML & CTF) (Version No. 2.5). This policy applies to all personnel and Agents & Sub-agents of Xpress Money. Money laundering & terrorist financing have been identified as major threats to the International Financial Services Community. Many governments have passed legislation designed to prevent these which impose certain requirements upon institutions registered in their jurisdiction. These legislations are a statement of the minimum standards to be adopted by all registered financial institutions operating in their jurisdiction. Xpress Money & its agents (including sub-agents) may be subject to different or more rigorous requirements of local regulation. In which case, the local requirements will be applicable, or in addition to, Xpress Money requirements. However XM has adopted best practices in the industry for AML & CTF Policy and Procedure. This Policy & Procedure will help you

• Detect and prevent money laundering & terrorist financing. • Identify suspicious activity; • Comply with your local laws and other AML&CTF regulations.

In addition to the above, you may assist law enforcement authorities in their effort to track down who illegally use their money for laundering & terrorist financing. Xpress Money has a responsibility to help fight money laundering & terrorist financing. As a company that operates in a wide variety of cultures, languages, and legal systems; present in several countries and has a large customer base, Xpress Money may be a target of would-be money launderers & terrorist financiers. We hope that you too will share this commitment to prevent our products and services, as well as your business, from being used for illegal purposes. Money laundering & terrorist financing is a crime that can lead to Losses, fines , seizure of accounts, cancellation of license, individual imprisonment for you and Xpress Money, as well as damage the reputation of both of our businesses if we do not take care. Working together, we can help prevent this illegal activity from occurring. Xpress Money Services Limited Anti Money Laundering & Combating Terrorist Financing Policy Framework set out in this document are divided into two sections: The 1st section sets out the Xpress Money Services Anti-Money Laundering & Combating Terrorist Financing Policy (AML&CTF Policy) and the second section outlines the Anti-Money Laundering Regulations for UK which, for the purposes of ensuring a uniform terminology within Xpress Money, is hereinafter also referred to as the “AML&CTF Policy”.

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Section One 1 General statements on “money laundering” 2 XM anti-money laundering principles 3 The XM AML&CTF Program 4 Risk Assessment & Mitigation

Section Two The second section of this document contains the UK Money Laundering Regulations which will be the standard of reference for all our agents operating in the UK. It consists of the following key elements: 1. Appointment of Compliance Officer/s 2. Customer Due Diligence & on-going monitoring of transactions 3. Anti-Money Laundering Training Program for Agents 4. Retention of records 5. Identifying and Reporting of Suspicious Activity 6. Penalty for non-compliance 7. Regular Review of Agents Anti-Money Laundering Program

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Section I - XM AML&CTF Policy 1. General statements on “money laundering” Money Laundering: Money Laundering is the process whereby criminals attempt to hide and disguise the true origin and ownership of the proceeds of their criminal activities thereby avoiding prosecution, conviction and confiscation of the criminal funds. The source of the proceeds may include drug trafficking, terrorism, organized crime, tax evasion, fraud and many other crimes. This process involves 3 steps: 1) Placement - physically placing cash proceeds. 2) Layering - piling of layers through complex financial transactions to separate the proceeds from illicit and/or criminal activity. 3) Integration - giving legitimate but false explanations as to the origin of the illicit monies. This definition covers a wide range of activity. Money launderers use a variety of means to launder money so that it cannot be easily detected. One of those means, may be is to convert currency into an Xpress money transaction. The purpose of this manual is to give you information that will help you identify money laundering and to help prevent it from occurring. Terrorism & Terrorist Funding: Terrorism can be defined as the unlawful use of force against persons or property to intimidate or coerce a government, the civilian population or any segment thereof, in the furtherance of political or social objectives. Terrorist acts are criminal in nature and constitute a serious threat to the individuals’ lives and freedom. Terrorist funding relates to provision or collection of funds to carry out an act of killing or seriously injuring a civilian with the objective of intimidating a section of people or compelling a government to do or to abstain from doing any act. Combating terrorist funding is one of the highest priorities for all the financial institutions across the world. The events of September 11th have placed the worlds financial institutions on the frontline in the battle against terrorist funding. The worldwide efforts to combat terrorist funding are gaining importance day by day. Terrorist funding is a global problem that not only threatens security but also compromises the stability, transparency and efficiency of the financial system. Elements of Terrorist Funding: • The primary objective behind terrorist funding is to intimidate or force a government or population to do or abstain from doing any act. In money laundering the objective is monetary gain. • The volume of remittances for terrorist funding need not have to be large as compared to money laundering. They will vary according to the strategies and methods adopted by the terrorists. • Terrorist funds need not be from illegal sources always. In some cases, funds are also sourced from legal income.

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What can we do to fight terrorist funding? Prevention - We have to prevent our products and services from used by terrorists for transferring their money. This can be done by applying appropriate “Know Your Customer” Policies and Procedures. Pursuit - We have to track down the terrorist transactions by blocking their names. In case you come across any blacklisted names, it has to be immediately reported to the concerned authorities. Protection - We have to protect our institution, our reputation, customers, our jobs and our communities where we operate. We have to protect by being responsible in our duties. If a counter agents does a money transfer transaction for a customer and has reasonable cause to suspect that it may be used, in whole or in part for the purpose of terrorism, and then it should be immediately reported the concerned Compliance Officer for necessary action. The fight against money laundering & terrorist financing is an evolving and never ending process. Money laundering not only harms the public as a whole, but it taints the financial services industry. It clearly is in the best interests of the financial industry to take all feasible action to prevent money laundering. Therefore we need to work together and co-operate to fight against the challenges posed by this social evil.

2. XM Anti-Money Laundering Policies Our policy has always been to conduct our business in compliance with all applicable laws and regulations. The fight against money laundering & terrorist financing is a priority for Xpress Money Services. We recognize that this fight is a team effort. We support the major international organizations, which collectively set and enforce standards for antimoney laundering & Combating terrorist financing policies and programs such as FATF (Financial Action Task Force), UN, The EU, The Organization of American States - The Office of Foreign Assets Control (OFAC) and the Local Regulatory Authorities in the UK (HMRC, FCA (formerly FSA), HMT & NCA). These organizations are increasingly insistent that compliance be assessed in terms of implementation and not simply concurrence with the policy standards or guidelines established. A high standard of Due diligence and fit & proper assessments are carried out prior to appointment of Xpress Money Agents. Xpress Money prohibits remittances to Charitable and Religious Organizations. Xpress Money gives special attention to transactions with or originating from countries identified by the FATF as being non – cooperative in combating money laundering & terrorist financing. As part of our enhanced due diligence commitment, we currently outsource the Services of World Check to keep in pace with the regularly updated database of suspected names (Watch / Black List) issued by various enforcement authorities in the USA and Europe. Our internal operating system maintains a realtime on-line interface with the service provider to ensure that all transactions are rigorously filtered, and timely action taken on exceptions. Xpress Money Transfer Transactions are limited to USD 5,000 or its equivalent in any foreign currency XM_UK AML/CTF Policy & Procedure

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worldwide on our system platform as part of our enhanced risk-mitigation approach to combating money laundering and terrorist financing. Through our cooperation with regulators across Europe, we aim to maintain the highest operating standards to safeguard the interest of our customers, our shareholders, our agents and the communities where we operate. In conducting business with due skill, care and diligence, Xpress Money seeks always to comply with both the letter and spirit of relevant laws, rules, regulation, codes and standards of good practice. We are continuously updating our systems and technology and training our agents to assure that we are well equipped to combat money laundering, terrorist financing and other financial crimes. We are fully committed to remaining constantly vigilant to prevent the use of our products and services by those who would abuse them.

3. The XM AML&CTF Program Nearly all countries worldwide meanwhile have adopted regulations on combating money laundering. The Financial Action Task Force (FATF), a global task force, has developed 40 recommendations on combating money laundering including 9 specific recommendations on combating terrorism financing (Now condensed into 40 New Recommendations in February 2012). These and other experiences from all countries in which XM is active are incorporated into the XM program which basically consists of seven measures. These at the same time are the global minimum standards applicable to all XM operations and their agents, and thus make sure that the principles set forth above are generally implemented. These instruments are: 1. Risk Assessment & Mitigation 2. Customer Due Diligence (otherwise known as KYC) 3. On-going monitoring of transactions 4. Anti-Money Laundering Training Program for Agents 5. Retention of records 6. Identifying and Reporting of Suspicious Activity 7. Independent review of the AML policies, principles and instruments. Money laundering and terrorism financing risks must be dealt with using risk-based approach. The 3rd EU Anti - Money Laundering Directive require that each MSB must adopt a new ‘risk-based approach’ to its customers, products and business practices.

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4. Risk Assessment & Mitigation XM Risk profile may be established both on the basis of objective criteria and subjective criteria. A ‘risk rating’ is given to each criterion based on the following rankings:

Grading 1 2 3 4 5

Risk Ranking Low Risk Low-Medium Risk Medium Risk Medium-High Risk High Risk

Below are summarized some of the operational risks that have been assessed and identified within our Company’s business as on December 2013. (subject to regular reviews):

Destination/Country Risks Country

Risk Factors

Risk Ranking

UK

This country is ranked 16 out of 180 with a risk factor CPI of 7.7 from 10 including the confidence rating of 7.2 - 8.1, which validates our assessment of risk as low.

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India

This Country is ranked 85 out of 180 with a risk factor CPI of 3.4 from 10 including the confidence rating of 3.2 - 3.6, which validates our assessment of risk as medium.

3

Bangladesh

This Country is ranked 147 out of 180 with a risk factor CPI of 2.1 from 10 including the confidence rating of 1.7 - 2.4, which validates our assessment of risk as high.

5

Pakistan

This Country is ranked 134 out of 180 with a risk factor CPI of 2.5 from 10 including the confidence rating of 2.0 - 2.8, which validates our assessment of risk as high.

5

Sri Lanka

This Country is ranked 92 out of 180 with a risk factor CPI of 3.2 from 10 including the confidence rating of 2.9 - 3.5, which validates our assessment of risk as medium.

3

Indonesia

This Country is ranked 126 out of 180 with a risk factor CPI of 2.6 from 10 including the confidence rating of 2.3 - 2.9, which validates our assessment of risk as medium - high.

4

United Arab Emirates

This Country is ranked 35 out of 180 with a risk factor CPI of 5.9 from 10 including the confidence rating of 4.8 - 6.8, which validates our assessment of risk as low -medium.

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Nepal

This Country is ranked 121 out of 180 with a risk factor CPI of 2.7 from 10 including the confidence rating of 2.4 - 3.0, which validates our assessment of risk as medium - high.

4

Philippines

This Country is ranked 141 out of 180 with a risk factor CPI of 2.3 from 10 including the confidence rating of 2.1 - 2.5, which validates our assessment of risk as high.

5

Morocco

This Country is ranked 80 out of 180 with a risk factor CPI of 3.5 from 10 including the confidence rating of 3.0 - 4.0, which validates our assessment of risk as medium.

3

Saudi Arabia

This Country is ranked 80 out of 180 with a risk factor CPI of 3.5 from 10 including the confidence rating of 3.0 - 3.9, which validates our assessment of risk as medium.

3

USA

This Country is ranked 18 out of 180 with a risk factor CPI of 7.3 from 10 including the confidence rating of 6.7 - 7.7, which validates our assessment of risk as low.

1

Vietnam

This Country is ranked 121 out of 180 with a risk factor CPI of 2.7 from 10 including the confidence rating of 2.4 - 3.1, which validates our assessment of risk as medium - high.

4

Sudan

This Country is ranked 173 out of 180 with a risk factor CPI of 1.6 from 10 including the confidence rating of 1.5 - 1.7, which validates our assessment of risk as high.

5

Jamaica

This Country is ranked 96 out of 180 with a risk factor CPI of 3.1 from 10 including the confidence rating of 2.8 - 3.3, which validates our assessment of risk as medium.

3

Ghana

This Country is ranked 67 out of 180 with a risk factor CPI of 3.9 from 10 including the confidence rating of 3.4 - 4.5, which validates our assessment of risk as medium.

3

Nigeria

This Country is ranked 121 out of 180 with a risk factor CPI of 2.7 from 10 including the confidence rating of 2.3 - 3.0, which validates our assessment of risk as medium - high.

4

Egypt

This Country is ranked 115 out of 180 with a risk factor CPI of 2.8 from 10 including the confidence rating of 2.4 - 3.2, which validates our assessment of risk as medium - high.

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Canada

This Country is ranked 9 out of 180 with a risk factor CPI of 8.7 from 10 including the confidence rating of 8.4 - 9.1, which validates our assessment of risk as low.

1

Kuwait

This Country is ranked 65 out of 180 with a risk factor CPI of 4.3 from 10 including the confidence rating of 3.3 - 5.2, which validates our assessment of risk as medium.

3

Malaysia

This Country is ranked 47 out of 180 with a risk factor CPI of 5.1 from 10 including the confidence rating of 4.5 - 5.7, which validates our assessment of risk as low -medium.

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It is company policy to consider and take note of any reports produced by the Financial Action Task Force (FATF) on ML/TF risks in particular countries. These are subject to regular changes and reviews in line with the source of this statistics at: www.fatf-gafi.org.

Transactions How are they processed ‘Face to Face’ ‘Non Face to Face’ MSB Registered ‘Face to Face’ and ‘Non Face to Face’

Risk Ranking 1 4 2

Size of Transaction Cash below GBP 600 Cash GBP 600 to 3000 Cash above GBP 3000

Risk Ranking 1 3 5

Customers Retail Customers In a business relationship occasional customers one off customers

Risk Ranking 1 3 4

ID Provided (retail customers/directors/owners of MSB) Type of ID Provided UK/EU Passports/driving licence (photo card) plus proof of address Non UK/EU Passport plus Resident Visa plus proof of address Any other form of other ID (‘unusual ID’)

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Risk Ranking 1 3 5

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Other Characteristics Description Customer is a PEP Customer is non-face to face (first transaction Customer is sanctions list match Customer is sending more money than would be justified by given employment status Customer is sending money on behalf of a group of other people Customer is otherwise behaving in an unusual way which may be suspicious(see below)

Risk Ranking 5 5 5 5 5 5

Unusual Activity which may be considered suspicious • Split transactions – the customer is attempting to split a large transactions into several smaller transactions to avoid obligations to provide ID or proof of source of funds • New customers carrying out large transactions (as opposed to regular customers) • Regular customer is processing transactions which do not match the profile of previous transactions • Customers processing transactions who do not appear to be legitimate owners of the funds (i.e. students processing large transactions) • Customers involved in transactions which appear to be linked to transactions processed by other customers • Customers who cannot provide ID when requested or who provide false ID • Customers who can not justify source of funds when requested • Customer is not local to the business, (but not a tourist) • Customer is paying in used notes or in small denominations • Transactions where customer is accompanied by another person who tells him what to do • Transactions which involve large numbers of GBP50 notes • The customer operates in a high risk area dealing in lots of cash: restaurants, pubs, casinos, tax firms, beauty salons and amusement arcades • Customers who are not native to the country they are sending money • Customer is processing large volume transactions in cash, (rather than sending funds from his personal bank account) • The transaction seems to be a “U-Turn Transaction” – Whereby the customer tries send back the money received to the same remitter or an attempt is seen to divert the funds to another country from where a further transfer is examined

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Risk Matrix - High, Medium and Low Risk Customers It will be the responsibility of the Money Laundering Reporting Officer (MLRO) and the Agent’s Compliance personnel to oversee all transactions which are processed. They will focus attention on high risk transactions (transactions with risk rating of 5). Risk Ranking 5

Summary of Red Flags Sanctions List Match

Action by Compliance Officer Freeze transaction and report to National Crime Agency (NCA)

5

Customer previously reported to NCA and NCA withheld consent

Freeze transaction and report to NCA

5

Customer provides fake ID

Freeze transaction and report to NCA

5

Customer previously reported to NCA and consent given Transaction being processed non face to face (and customer not previously identified)

Freeze transaction pending enhanced due diligence check Enhanced Due Diligence required

5

Cash transaction above GBP3000 (and no source of funds established)

Enhanced Due Diligence required

5

Retail customer has sent cash transactions above GBP15000 within 12 month period (and no source of funds established)

Enhanced Due Diligence required

5

Customer is PEP

EDD required

5

Customer uses unusual ID to identfy himself

EDD required

5

Customer is processing level of transactions incompatible with work status

EDD required

5

Customer is demonstrating unusual behaviour (which may be suspicious)

EDD required

5

Customer is an MSB who is transacting outside anticipated parameters set at start of business relationship

EDD required

5

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5

Customer is an MSB and ownership is not clear/MSB not able to verify ownership

4 or less

EDD required

No action rquired

There are no globally accepted criteria or a binding list, but the following customer profiles are especially vulnerable to money laundering and therefore must be always subjected to intensive examination: •Manufacturers of and traders in arms and ammunition; • Business models involving large amounts of cash; • Jewellers; • Traders in luxury goods; • Auctioneers; • Real estate agents; • Second-hand car dealers; •Top-ranking politicians and senior government officials as well as their relative Politically Exposed Persons (PEPs); • Professional trustees such as tax consultants, lawyers, trustees, notaries who act as an interface to transaction processes and integrate their clients’ monies into the money flow during the “Layer” phase; •Financial institutions such as offshore banks, letterbox companies, and secret enterprises. Products and services involving risks are those which: •Are identified by the regulatory authorities; •Enable participants to remain anonymous;

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Section II Anti-Money Laundering Procedures (AML&CTF) for Agents operating in the UK Applicable AML Regulations in the UK All Money transmitters (whether Independent or Agents) providing XM regulated payment services and products in UK are bound by the following legal requirements and relevant provisions contained in: • Money Laundering Regulations 2007 (as amended) • Proceeds of Crime Act 2002 (PoCA 2002) • Counter-Terrorism Act 2008 (CTA 2000) • Payments Services Regulation 2009 The UK Money Laundering Regulation criminalizes money laundering related to narcotics trafficking, fraud, forgery, embezzlement, and membership in a terrorist organization. It also increases due diligence and reporting requirements for Payment Institutions like XM and its agents, and requires us to obtain customer identification for transactions conducted and verify them accordingly. XM or their Agents must report suspected money laundering to the National Crime Agency (NCA) XM Agents operating in UK must be aware of their regulatory obligations herewith highlighted for their guidance and compliance:

1.0 Appointment of Compliance Officers Every Agent must appoint a compliance officer who will act directly as contact person for the Regulatory Authorities (like HMRC, FCA and HMT) and the National Crime Agency (NCA). The officer may be the agent himself (if a sole trader) or a staff with sufficient authority who will be responsible for the following functions: • Implement or monitor the implementation and execution of the provisions of the Anti-Money Laundering Regulations, the directives issued by HMRC or FCA or other supervising entities and XM internal policies and procedures. • Identify and make Suspicious Transaction Reports (STR), investigate and report to the competent authorities, if required. • Coordinate with the Regulatory Authorities in money laundering and terrorist financing issues and provide any information requested including relevant documentation and audits • Monitor Agent activities and take reasonable steps to ensure compliance with the AML&CTF Policy & Procedures. • Monitoring day-to-day transactions of the Agent for any unusual/ structured/ suspicious/ blacklisted ones. • Performing more extensive due diligence for high risk amounts/ countries/ customers and include proactive monitoring for suspicious activities. • Educate the Agent and the frontline staff regarding Anti-Money Laundering & Combating Terrorist Financing and ‘Know Your Customer’ procedures. • Ensure effective arrangement is in place to comply with record keeping requirement. • Liaise with the XM appointed MLRO based in the UK for support and guidance regarding the aforementioned functions XM_UK AML/CTF Policy & Procedure

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1.1 XM MLRO shall ensure that all newly appointed agents have been previously subjected to ‘fit and proper test’ criteria before their appointment. In applying the fit and proper test, XM generally takes into account the following factors: the person’s reputation and character, the person’s knowledge and experience, and past record, if any, of non-compliance or criminal activity. The XM MLRO contact details are given below for your information: Adeleke Aina XM Money Laundering Reporting Officer (MLRO) E-mail: [email protected] Tel: +44 207 478 0712

2.0 Customer Due Diligence and Monitoring of transactions 2.1 What is customer due diligence? The UK Money Laundering Regulation requires all our Agents operating in the UK to perform the following Customer Due Diligence : • To identify and verify the identity of customers; • To keep copies of identity and verification results • To obtain information on the type of business relationship they have with their customers, where not evident; • To identify, where applicable, the “beneficial owner” involved in the business or transaction and take risk-based and adequate measures to verify their identity; • To continuously monitor the business relationship including the update of the documentation in reasonable intervals. The above instances MUST be done whenever any of the following occurs:

• Whenever business relationship is to be established with any customer • Whenever cash transaction is carried out that will be in excess of XM stipulated limit of £599.99 or multiple / split transactions adding up to £600 • Where there is a reason for suspicion of money laundering or terrorist financing regardless of the amount involved • Where there are doubts about previously obtained customer identification information

2.2 Non-compliance with customer due diligence measures Where an agent is unable to comply with the required CDD measures in relation to a customer as stated above, then the agent: • Must not carry out any transaction for the customer • Must not establish a business relationship • Must terminate any existing business relationship with the customer • Must consider making a report to the National Crime Agency (NCA) either by phone or via their on-line website XM_UK AML/CTF Policy & Procedure

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If the problem is caused by the customer not having the “right” documents or information (perhaps because the person is financially excluded, i.e. not having any banking relationship), consideration should be given to whether there are any other ways of being reasonably satisfied as to the customer’s identity. If there are no grounds for making a report to NCA, the business should return any funds already received, ideally in a way that minimizes the risk of the returned funds being effectively laundered in the process. If the business decides that the circumstances give reasonable grounds for knowledge or suspicion of money laundering or terrorist financing, the agent must contact the XM MLRO for guidance.

2.3 Identifying the beneficial owner 2.3.1 General legal requirements: A “beneficial owner” is the individual behind the customer who ultimately owns or controls the customer or, as the case may be, the person who causes a transaction to be executed or on whose behalf a transaction or activity is ultimately being conducted or the business relationship is being established. The Regulation requires agents to identify the “beneficial owner” of the customer funds and take riskbased and adequate measures to verify his identity. These due diligence obligations are slightly different from the obligation to verify the identity of customers in that there is no requirement, when identifying beneficial owners, for verification to be done on the basis of documents, data or information obtained from a reliable and independent source. We must only take risk-based and adequate measures with the objective of satisfying itself that it knows who the beneficial owner is. Where there are difficulties in independently verifying information provided on beneficial owners, the businesses should review the information provided by the customer and seek further evidence, where considered necessary. A decision should then be made, based on the information provided on the beneficial owner(s), the rationale for the transactions and the risks involved, as to whether the evidence of identity of the beneficial owner is satisfactory to enable the business relationship to be established or the occasional transaction to be carried out. 2.3.2 Beneficial owners of corporate bodies: The beneficial owners of companies (bodies corporate as well as partnerships) are the individuals who ultimately own or control (whether direct or indirect) more than 25% of the shares or voting rights in the company. 2.3.3 Beneficial owners of incorporated foundations and of any construct managing assets on a trust basis as well as similar constructs This means any constructs where assets are collected or managed jointly or by a third party (trustee) and where both the assets and the income therefrom is intended for the benefit of the depositors themselves or any third parties. In these cases the beneficial owner is: • Any individual controlling at least 25% of the assets; or who is • The beneficiary of 25% or more of the assets under management; or • The group of future beneficiaries, if the ultimate beneficiary has not yet been determined; or • Any individual who otherwise controls the assets under management. XM_UK AML/CTF Policy & Procedure

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2.4 Enhanced due diligence (EDD) General legal requirements: Agents are required to apply enhanced due diligence measures on a risk-sensitive basis: • When the customer has not been physically present for identification purposes • In respect of a business relationship or occasional transaction with a “politically exposed person” (PEP) • If any of regulatory agency directs that such measures should be applied • In any other situation which by its nature can present a higher risk of money laundering or where the specific circumstances of a transaction are dubious or unusual. The measures to be taken will depend on the situation which triggers enhanced due diligence.





2.4.1 Non face-to-face customers Where the customer has not been physically present for identification purposes, specific and adequate measures must be taken to compensate for the higher risk. The Regulations requires the following: • A valid official identification document (Government-issued identity card or passport, UK or EU member state Drivers Licence) must have been presented in original or certified copy must have been provided. In such case the initial transaction must originate from an account opened in the name of the customer with a credit institution (Banks). • The verification of identity by a digital proof of identity pursuant to JMLSG guidance is also possible. • Politically Exposed Persons. Enhanced due diligence measures must be taken for these persons, too. Such measures are discussed in more detail further below

2.5 Nature and purpose of the business relationship The purpose of obtaining information on the customer is to build a base-line of knowledge of the customer and his business. Understanding the purpose of the transactions, the source and destination of the remitted funds, and the nature of the customer’s business, enables us to have some expectation regarding the size and frequency of transactions. We can then identify unusual transactions that require scrutiny to decide whether further customer due diligence measures or suspicious activity reporting action is necessary. Useful information could include: • The customer’s line of business or work • The purpose of the transactions • The expected frequency of transactions • The nature of the payer’s relationship with the payee • Other general circumstances of the customer. For business customers, further information includes: • Turnover of the business, its size, and its number of agents • Length of establishment. As the nature of this information is likely to change over time, the law requires a process of review and updating of information about the nature and purpose of the relationship where this changes over time. XM_UK AML/CTF Policy & Procedure

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2.6 Customer Identification 2.6.1 Individuals: For natural persons the following information should be obtained, where applicable: All relevant details of the ID should be taken on record such as • legal name (as appearing in primary ID) and any other names used (such as maiden name); • correct permanent address (the full address with post-code should be obtained; a Post Office box number is not sufficient); • telephone number, fax number, and e-mail address; • date and place of birth; • nationality; • ID number, Date and Place of Issue/Country & Date of Expiry; • occupation (employed or self-employed), public position held and/or name of employer; • an official personal identification number or other unique identifier contained in an unexpired official ID document (e.g. passport, identification card, residence permit, social security records, driving licence) that bears a photograph of the customer;

The photocopy of the document is to be stamped “True copy of the Original” and signed by the attending agents. Examination of the documents should be carried out carefully and satisfied as to the following:

• validity of the ID • his physical appearance should match with photo identity • original signature should match with that found on the ID

Before conducting any transaction, the Agent shall identify the customers with any one or more of the original documents referred hereunder: • confirming the date of birth from an official document (e.g. birth certificate, passport, identity card, social security records); • confirming the permanent address (e.g. utility bill, tax assessment, bank statement, a letter from a public authority); • contacting the customer by telephone, by letter or by e-mail to confirm the information supplied after an account has been opened (e.g. a disconnected phone, returned mail, or incorrect e-mail address should warrant further investigation);

Please see Appendix I for summary of XM Money Transfer Requirements 2.6.2 Corporate Entities For corporate entities (i.e. corporations and partnerships), the following information should be obtained: • Name of the company or other identifiers; • Legal form of the company; • Full name(s) of the member(s) of the company’s representative bodies or of the legal representative(s). If any of such members or representatives itself is a body corporate, the appropriate information must be obtained on them too • Principal place of company’s business operations; • Mailing address of company; XM_UK AML/CTF Policy & Procedure

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• Some form of official identification number (e.g. company registration number); • Extract from a relevant register (company, association, cooperative, partnership register, etc.); • The original or certified copy of the Certificate of Incorporation and Memorandum and Articles of Association; • Identification of those who have authority to operate the account; • Nature and purpose of business and its legitimacy.

You should verify this information by the following methods:

• For established corporate entities - reviewing a copy of the latest report and accounts (audited, if available); • Undertaking a company search and/or other commercial enquiries to see that the institution has not been, or is not in the process of being dissolved, struck off, wound up or terminated; • Utilizing an independent information verification process; • Obtaining prior bank references; • Visiting the corporate entity; • Contacting the corporate entity by telephone, mail or e-mail.

2.7 Documentary evidence 2.7.1 Natural Persons The following documents are acceptable form of identification under the UK regulations: • Documents issued by government departments and agencies, or by a court, then • Documents issued by other public sector bodies or local authorities, then • Documents issued by regulated firms in the financial services sector We should recognise that some documents are more easily forged than others. If suspicions are raised in relation to any document offered, we should take whatever practical steps are available to establish whether the document offered has been reported lost or stolen. The identity card or an official substitute document bearing a photograph. Any other documents must only be accepted as proof of identity after a thorough investigation of the individual case and only if the reason why no official documents exist can be established satisfactorily. Checks on photo ID may include: • Visual likeness against the customer • Does the date of birth on the evidence match the apparent age of the customer? • Is the ID valid? • Is the spelling of names the same as on other documents provided by the customer? Checks on secondary evidence of ID may include: • Do the addresses match the address given on the photo ID? • Does the name of the customer match with the name on the photo ID?

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Consideration should be given as to whether the documents relied upon may be forged. In addition, if a business chooses to accept documents that are in a foreign language, appropriate steps should be taken to be reasonably satisfied that the documents in fact provide evidence of the customer’s identity. 2.7.2 Corporate customers The following must be considered additionally with regard to corporate customers The structure, ownership, purpose and activities of many corporates will be clear and understandable. Some use complex ownership structures which can increase the steps to be taken to be reasonably satisfied as to their identities but this does not necessarily indicate a risk of money laundering or terrorist financing. The use of complex structures without an obvious commercial purpose may, however, give rise to concern and indicate an increased risk of money laundering or terrorist financing. To the extent consistent with the risk assessment carried out a business should ensure that it understands the company’s legal form, structure and ownership, and should obtain sufficient additional information on the nature of the company’s business, and the reasons for seeking the product or service. In general the structure, ownership, purposes and activities of many private companies will be clear and understandable. The standard evidence in the section above on corporate customers should be obtained and verified, plus, additionally and as far as not already done, the following information should be obtained and verified: Names of all directors (or equivalent) Names of beneficial owners holding over 25% Names of all executives (or equivalent).

2.8 Electronic evidence Most customers who live in the UK will have built up an electronic “footprint”, i.e. a profile of checks that have been made, for example by utility providers, telephone companies, credit agencies, banks etc. Over time, individuals build up a score which is based on the number of checks made, the range of sources the information has been verified from etc. It is the score that determines the reliability of the electronic information held. We can access these records, either directly or through an independent third party organisation, and use them as a way of confirming customers’ details. This can provide a useful basis for having confidence in a customer’s identity. N.B. Checks made for this purpose don’t require the customer’s permission but they must be informed that the check is to take place.

Please see Appendix II for detail listing of XM Acceptable form of Identity 2.9 On-going monitoring The regulations require XM and Agents to put a system in place that will facilitate the review and monitoring of the money laundering and terrorist financing risks to the business. The risk-based approach by the business will be informed by the monitoring of patterns of business, for example: • A sudden increase in business from an existing customer • Uncharacteristic transactions which are not in keeping with the customer’s known activities XM_UK AML/CTF Policy & Procedure

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• Peaks of activity at particular locations or at particular times • Unfamiliar or untypical types of customer or transaction.

Agents must ensure that appropriate controls are put in place to lessen these risks and prevent the business from being used for money laundering or terrorist financing. Managing and mitigating the risks will involve: • Applying customer due diligence (Know Your Customer) measures to ask for and verify the identity of customers and any beneficial owners • Obtaining additional information on higher risk customers • Conducting on-going monitoring of the transactions and activity of customers with whom there is a business relationship • Having a method to identify and check unusual transactions to determine whether there are reasonable grounds for knowing or suspecting that money laundering or terrorist financing may be taking place. • Agents awareness and training • Keeping records of identity, verification and other supporting records for a minimum of 5 years beginning on the date from which a transaction is completed Examples of risk-based control procedures may include: • Introducing customer identification and verification procedures at a lower monetary level than the minimum set out for occasional transactions in the Money Laundering Regulations in circumstances where the customer or other characteristics of the transaction are in a higher risk category. This applies to all cases of cash transfer of £600 and above • Requiring ID evidence – whether it be documentary, electronic or third party Assurance – to be of a certain standard • Requiring additional evidence of identity in higher risk situations. E.g. source of funds for transactions above £2000 • More extensive due diligence checks, for example, on source of funds for higher risk customers • Varying the level of monitoring of customer transactions and activities according to identified risk to identify transactions or activities that may be unusual or suspicious.

2.10 Other higher risk situations: 2.10.1 Politically exposed persons (PEPs) Under the definition, a politically exposed person is a person who: • Is or has in the past been entrusted with a prominent public function by – (i) A state other than the UK (ii) A Community institution (e.g. the European Parliament) or (iii) An international body (e.g. the U.N.) or • Is an immediate family member or a “known close associate” of such a person. Prominent public functions include: • Heads of state or government, ministers and deputy or assistant ministers, state secretaries, Members of parliaments, Members of supreme or constitutional courts, or other high level judicial bodies the decisions of which cannot be appealed against any more; Members of courts of auditors or the board of central banks • Ambassadors, charges d’affaires and high-ranking officers in the armed forces and • Members of the administrative, management or supervisory bodies of State-owned enterprises. XM_UK AML/CTF Policy & Procedure

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An “immediate family member” includes: • A spouse • A partner • Children and their spouses or partners and • Parents. A “known close associate” includes: • Any individual who is known to have joint ownership of a legal entity or legal arrangement, or any other close business relations, with a person referred to in the above bullet points and • Any individual who has sole beneficial ownership of a legal entity or legal arrangement which is known to have been set up for the benefit of a person referred to in the above bullet points. How can a PEP be identified? We must identify when a customer with whom we propose to have a business relationship or carry out an occasional transaction is a PEP. Where there is a risk that such a customer may be a PEP, we should make appropriate enquiries by, for example, asking the customer for background information, researching publicly available information via the internet, or, if the risk is substantial, consulting a commercial website listing PEPs. If there is doubt about whether the customer is a PEP, the customer should be treated as high-risk. In deciding whether a person is a known close associate of a PEP businesses need only have regard to information that they hold or is publicly known. What customer due diligence measures must be applied to PEPs? When we propose to have a business relationship with, or conduct occasional transactions with a politically exposed person we must apply enhanced due diligence measures on a risk-sensitive basis. They must: • Have senior management approval for establishing a business relationship with such a person • Take adequate measures to establish the source of wealth and source of the funds involved • Conduct enhanced on-going monitoring of the business relationship. 2.10.2 Enhanced Due Diligence Enhanced due diligence measure are applied in situations which by their nature can present a higher risk of money laundering or terrorist financing. We must be capable of identifying such situations and appropriate enhanced due diligence measures must be applied to mitigate the risk involved. For example, enhance due diligence measures could include: • Obtaining details of the source of the customer’s funds and the purpose of the transactions • Obtaining additional evidence of identity • Applying supplementary measures to verify or certify the documents supplied or requiring certification by a credit or financial institution • Ensuring that the first payment of the operations is carried out through an account opened in the customer’s name with a credit institution. 2.10.3 Blacklisted Entities and Individuals XM shall continually obtain information of Black Listed Entities and Individuals from the enforcement authorities and international Agencies and update the same in the system. All transactions irrespective of the amount shall be scanned against the Blacklist database. If there is any name match of the customer/beneficiary, the transaction shall be immediately suspended for enhanced due diligence checks. The customer/beneficiary details of the suspended transaction shall be checked against the blacklist database and if different, shall be revoked. If there is an exact match, the XM_UK AML/CTF Policy & Procedure

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transaction shall be blocked and reported to the NCA. The FATF recommends that special attention should be given to business relations and transactions with persons including companies and financial institutions from the “Non-Cooperative Countries and Territories” (NCCT). In case there is any doubt that a transaction is meant for terrorism or terrorism organization or terrorist purposes, XM shall freeze the transaction and inform the NCA in writing immediately.

3.0 Anti-Money Laundering Training for Agents 3.1 XM shall provide periodic anti-money laundering and counter terrorist financing training to their Agents. Agents should also be aware of their own personal legal obligations/ responsibilities under the regulations and that they can be personally liable for failure to train their frontline staff. The training shall include the following: • Responsibility of the Agents under the Money Laundering Regulations for obtaining sufficient evidence of identity, recognizing and reporting knowledge or suspicion of money laundering and terrorist financing. • Duties and responsibilities of the Agents (as per XM Global AML/CTF policy and the procedures for UK.) • Procedure for reporting of suspicious transactions. • Potential effect on the company, on its agents and customers if there is any breach of law or regulation. • Ways to identify suspicious transactions. • Record Retention. 3.2 AML&CTF are also covered in the introductory training given to new agents. New agents, who will be dealing with customers or their transactions, irrespective of the level of seniority, shall have a general appreciation of the background about money laundering, the consequent need to be able to identify suspicious transactions and report such transactions to the appropriate designated XM MLRO, and the offence of “tipping off”. They shall be made familiar with the legal requirement and their personal statutory obligation to report suspicious transactions relating to drug trafficking or other indictable offences.

4.0 Retention of Records General legal requirements We will only be successful in demonstrating our compliance with the requirements of the regulations through keeping evidence and records of a. Due diligence checks made and b. Information held on customers and transactions. These records may be crucial in any subsequent investigation by NCA, the police or HMRC. They will enable the business to produce a sound defence against any suspicion of involvement in money laundering or terrorist financing, or charges of failure to comply with the Regulations. XM_UK AML/CTF Policy & Procedure

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The records that must be kept The records that must be kept are: • A copy of, or the references to, the evidence of the customer’s identity obtained under the customer due diligence requirements in the Regulations. Clear copies of the forms of identification presented by customers, or a record of where they can be obtained, should be retained. • The supporting evidence and records in respect of the business relationships and occasional transactions which are the subject of customer due diligence measures or on-going monitoring. Records must be kept and should include the name and address of the customer. In relation to the evidence of a customer’s due diligence businesses must keep the following records: • All copies of documents accepted and verified as evidence for conduct of due diligence and • All other References to the evidence of customer’s identity • Transaction and business relationship records (e.g. account files, relevant business correspondence, daily log books, receipts, cheques etc.) should be maintained in a form from which a satisfactory audit trail may be compiled, and which may establish a financial profile of any suspect account or customer. How long the customer due diligence records must be kept? Evidence of customer’s identity records must be kept for five years beginning from the end of the year during which the date of completion of the transaction or the termination of the business relationship occurred. The same retention period applies to records of transactions (whether undertaken as occasional transactions or part of a business relationship). In what format must the records be kept? Records may therefore be kept: • By way of original documents • By way of good photocopies of original documents • In scanned form • In computerised or electronic form. It must be ensured, however, that the data stored electronically is consistent with the original document.

5.0 Identifying and Reporting of Suspicious Activity Suspicious Activity reporting to the National Crime Agency (NCA) 5.1 General legal and regulatory obligations All agents are required to disclose information to the XM MLRO when they Know or suspect or have reasonable grounds for knowing or suspecting that another person is engaged in money laundering or terrorist financing MLRO will determine whether the information received gives rise to knowledge or suspicion or reasonable grounds for knowledge or suspicion of money laundering or terrorist financing before reporting to the National Crime Agency (NCA). XM_UK AML/CTF Policy & Procedure

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5.2 Internal reporting procedures All agents must report suspicious activity to the XM Money Laundering Reporting Officer. A report will be made as soon as a decision is made that there are reasonable grounds to suspect money laundering. Suspicion may arise before or after a transaction takes place. Before deciding to make a report to NCA, the MLRO will need access to all the business’s relevant records. The agents should inform • The financial circumstances of the customer or a person on whose behalf the customer is acting and • The details of the transaction. In addition, the Money Laundering Reporting Officer will: • Consider the level of identity information held on the customer and any information held on his personal circumstances that might be available to the business and • Review other transaction patterns and volumes through the account and any other accounts in the same name. The Money Laundering Reporting Officer should also take into consideration any additional risks where the customer is located outside the UK, particularly if the customer is located in a high-risk jurisdiction. If the Money Laundering Reporting Officer decides not to make a report to NCA, the reasons for not doing so should be clearly documented or recorded electronically, and retained with the internal suspicion report.

Please see Appendix III for Suspicious Transaction Report (STR) form to be used by agents. 5.3 Consent to a transaction Where a customer’s transaction request raises grounds for suspicion of potential money laundering or terrorist financing activity, consent must be sought from NCA before the transaction is completed, unless it is not practicable to do so (see below). We have to give a written report to NCA containing the suspicious transaction and the background which gives reason for the suspicion. A suspicious transaction can in cases of urgency be reported by phone (then a written report as to be followed up as soon as possible). Beginning the day after NCA receives the report it has seven (7) working days to react (Monday-Friday deemed as working day). If there is no explicit response or consent from NCA to perform the reported transaction within seven working days, the transaction can proceed, although good practice should include further contact with the NCA to ensure a notice of refusal hasn’t been sent. If it is not possible to suspend a transaction in order to obtain the reporting procedure, for reasons of urgency or because the report procedure would hinder the tracking/prosecution of the beneficiaries of the transaction, a suspicious activity report must be submitted as soon as possible after the transaction is completed. You will need to demonstrate that you have a good reason for not seeking prior consent to the transaction. If you are unable to provide adequate justification for not performing the reporting procedure you may be liable to prosecution under the Proceeds of Crime Act. In any case not to report a suspicious transaction makes you liable to prosecution under this Act. XM_UK AML/CTF Policy & Procedure

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5.4 Tipping Off Agents or Staff must not tell a customer: • That a transaction was/is being delayed because consent from NCA has been requested • That details of their transactions or activities will be/have been reported to NCA • That they are being investigated by law enforcement. To act against this obligation may be liable to prosecution too. However, reasonable enquiries of a customer concerning the background to a business or transaction, as part of customer due diligence checks will not give rise to a tipping-off offence. 5.5 Suspicion indicators The following lists are not exhaustive but set out some of the main indications that a transaction is suspicious. 5.5.1 New customers and occasional or “one-off” transactions: • Checking identity is proving difficult • The customer is reluctant to provide details of their identity • There is no genuine reason for the customer using the services of an MSB • A cash transaction is unusually large • The cash is in used notes and/or small denominations • The customer requests currency in large denomination notes • The customer will not disclose the source of cash • The explanation for the business and/or the amounts involved are not credible • A series of transactions are structured just below the regulatory threshold for due diligence identity checks • The customer has made an unusual request for collection or delivery • Transactions having no apparent purpose or which make no obvious financial sense, or which seem to involve unnecessary complexity • Unnecessary routing of funds through third parties. 5.5.2 Regular and established customers • The transaction is different from the normal business of the customer • The size or frequency of the transaction is not consistent with the normal activities of the customer • The pattern of transactions has changed since the business relationship was established • Money transfers to high-risk jurisdictions without reasonable explanation, which are not consistent with the customer’s usual foreign business dealings • Sudden increases in the frequency/value of transactions of a particular customer without reasonable explanation.





5.5.3 Examples where customer identification issues have potential to indicate suspicious activity • The customer refuses or appears reluctant to provide information requested • There appears to be inconsistencies in the information provided by the customer • The customer’s area of residence is inconsistent with other profile details such as employment • An address appears vague or unusual • The supporting documentation does not add validity to the other information provided by the customer XM_UK AML/CTF Policy & Procedure

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•The customer is in a hurry to rush a transaction through, with promises to provide the information later.



5.5.4 Examples of activity that might suggest to agents that there could be potential terrorist activity • The customer is unable to satisfactorily explain the source of income • Frequent address changes • Media reports on suspected or arrested terrorists or groups. The Company’s directors, officers and agents must not warn or inform their customers when information relating to them are being reported to /investigated by the relevant authorities. By ignoring key indicators on money laundering/terrorist financing, an agent is considered to have directly partaken in such a scheme through “wilful blindness”. Wilful Blindness is a situation when an agent, or staff becomes suspicious about a customer / transaction but did not report his/her suspicions, even though he/she is aware that the transaction is of an illegal nature or that the purpose of the customer’s transaction is for money laundering/terrorist financing.

6.0 Supervision & Penalty for Non-Compliance 6.1 Administrative Supervision • The competent regulatory authority for the enforcement of the AML regulations for Money Transmission Companies in UK will continue to be the HM Revenue & Customs • The competent regulatory authority for the regulation of payment services provided by Money Transmission Companies in UK under the Payment Services Directive will continue to be the Financial Conduct Authority (FCA) • Our Agents and Staff shall, upon request and free of charge, provide HMRC or FCA as well as persons and institutions working under them, with information on all business matters and shall produce any documents relevant to compliance with the requirements laid down in the UK Money Laundering Regulations. • HMRC or FCA may also, without specific reason, conduct examinations of compliance with AML requirements at the offices or premises of the Agent at any time during business hours. • The Agents are advised not to refuse to provide HMRC or FCA with any information in response to any questions the answering of which would place them as liable to criminal prosecution or proceedings under the Regulation • XM will regularly provide Agent Company with up-to-date interpretation and practice notes to implement the due diligence requirements and internal controls and safeguards as set forth in the UK regulation. • XM should be notified in good time prior to changes regarding the Agent’s activities in UK as well as changes in the name, address and registered office details. The changes should be notified to XM well before the actual effective date the changes take effect.

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6.2 Fines & Penalties An administrative offence shall be deemed to be committed by any Staff or Agent who wilfully or gross negligently: • fails to identify the contracting party or customer correctly, completely, in the prescribed manner, in due time or at all times or fails to identify the customer when accepting cash transaction in the prescribed manner consistent with the regulations described in this document and in accordance with the UK AML regulation; • fails to establish clarity regarding the existence of a beneficial owner, or fails to do so correctly, completely or in due time; • fails to establish the name of the beneficial owner; • fails to verify the identity of the customer correctly, completely or at all, or fails to ensure that the first transaction is carried out from an account opened in the name of the customer; • fails to record any data or information correctly, completely or at all; • fails to keep records and other evidence for at least five years or at all; • fails to file a report correctly, completely, in due time or at all; • discloses information to the customer or instructing party or any third party; • fails to provide any information correctly, completely or at all or fails to produce any documents correctly, completely, in due time or at all; or fails to tolerate any measure specified thereunder. The administrative offence may incur up to between 2 – 5 years imprisonment and/or an unlimited fine.

7.0 Independent review of Anti-Money Laundering Program The MLRO will conduct independent review of the AML Procedures on a regular basis His review will cover the following areas: • Customer Registration • Outward & inward Transfers • On-going monitoring reviews • Quality of record keeping • Suspicious Transaction Reporting • Agent Staff Training • Customer Satisfaction Apart from this the XM internal auditors shall conduct their periodical AML audit separately.

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APPENDICES Appendix I - Summary of XM Money Transfer Requirements Agents are to ensure that the following requirements are correctly recorded in the system (and copies retained where applicable) at the time of processing the transfer: SEND

TRANSACTIONS (BELOW £600) (a) Sender’s full name and address (b) Sender’s telephone number (c) Receiver’s full name, address and telephone number (d) Details of valid photo ID of the Sender to be incorporated in each transfer instruction. (e) Purpose of transfer and Source of fund details (f) Signature of the Sender and Agent

SEND

TRANSACTIONS (£600 TO £1999.99) (a) Sender’s full name and address (b) Sender’s telephone number (c) Sender’s valid photo identification number, type, issuing state/country (copy of ID to be retained by agent) (d) Receiver’s full name, address and telephone number. (e) Purpose of transfer and Source of fund details (f) Signature of the Sender and Agent

SEND TRANSACTIONS (£2000 and above) (a) Sender’s full name and address (b) Sender’s telephone number (c) Sender’s photo identification number, type, issuing state/country (copy of ID to be retained by agent) (d) Sender’s Date of birth & occupation (e) Purpose of Remittance to be recorded (supporting documents to be provided in case of “business”) (f) Source of Remittance to be recorded (proof to be provided and copy retained by agent) (g) Receiver’s full name, address and telephone number (h) Signature of the sender and Agent RECEIVE TRANSACTIONS (ALL AMOUNTS) (a) XPIN number (b) Receiver’s full name, address and telephone number (c) Receiver’s photo identification number, type, issuing state / country (copy to be retained with the application) (d) Sender’s name and the amount to be taken from the receiver for crosschecking the details. (e) Signature of the receiver (f) Apart from the above, any other requirement of the local laws to be fulfilled.

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Appendix II - XM Acceptable Form of Identity Primary ID a.

Secondary ID

EU/UK Government-Issued documents with a photograph: - Valid Passport (If the passport is non – EU, valid resident None permit issued by Home Office to be requested in addition.)

Valid photocard driving licence (full or provisional) ID card issued by the electoral office of N. Ireland b.

None None

UK Government-Issued documents without a photograph: Valid old style full UK Driver’s Licence + secondary ID Recent evidence of entitlement to state or local authority funded benefit, tax credit, pension or other grant + secondary ID Court Order + secondary ID

Any National passport or any form of ID with photograph Any National passport or any form of ID with photograph

Any National passport or any form of ID with photograph Current council tax demand letter + Any National passport or any form of ID with secondary ID photograph Current bank or credit/debit card statement + Any National passport or any form of ID with secondary ID photograph Original Utility bills (not printed off internet) + Any National passport or any form of ID with secondary ID photograph c.

ID requirement for financially-excluded customers Economic Migrants - National passports + secondary requirement Refugees - Immigration status document + secondary requirement Asylum seekers - IND Application Registration Card + secondary ID

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Any other utility documents to show proof of address in the UK Any other utility documents to show proof of address in the UK Any National passport or any form of ID with photograph

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Appendix III – Suspicious Transaction Reports (STR) Form to be used by Agents Private and Confidential SUSPICIOUS ACTIVITY REPORT (SAR) To: XM Money Laundering Reporting Officer From:........................................................................ (name of Agent) Phone # of Agent: Date: This SAR (underline which applies) is: 1. A request for consent for a transaction which is not yet completed 2. A report on a transaction which has taken place which I consider suspicious

Yes / No Yes / No

3. Report on other person or business related activity which I consider suspicious Yes / No I consider the following transaction suspicious and report to you under the XM internal reporting procedure. 1) Date of transaction : 2) Amount involved (if any): 3) Name of suspected person or business*: 4) Address of suspected person or business*: 5) Date of Birth (if known): 6) Transaction number (if any): 7) Please state your reason for suspicion*:

__________________________ Signature of Agent Signature not necessary if you are sending this report as email attachment *It is compulsory you provide this information

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Appedix IV - Xpress Money Source Of Fund Declaration ForM Agent Name

Agent Code

Agent Address

Sender’s Name Sender’s Address

Transfer Amount in GBP Transfer Destination

Source of the money (please tick where applicable)

Proof provided

i. Salary/wages from Employment

ii. Income from Self Employment

iii. Gift / Donation

iv. Other sources (please state)

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Appendix V – Documentation Checklist for Agents Application 1) Sole Proprietorship Firm a) Govt-Issued Photo identification document of the Proprietor and the Witness (Who signs the contract). Evidence of Authorization to work in the EU country must be included. b) Proof of business and personal Addresses (Utility Bill such as BT, Gas, Electricity or Council Tax or Bank Statement) c) Duly Completed information sheet d) Duly Completed AML Questionnaire e) Duly completed Agent KYC Check list f) Duly completed Certification of Compliance g) Agent’s Internal AML/CTF Policies & Procedures and controls in place for the prevention of Money Laundering and Terrorist Financing. h) Business Licence required for EU Agents 2) Partnership Firm a) Govt-Issued Photo identification document of the Proprietor and the Witness (Who signs the contract). Evidence of Authorization to work in the EU must be included b) Proof of business and personal Addresses (Utility Bill such as BT, Gas, Electricity or Council Tax or Bank Statement) c) Duly Completed information sheet d) Partnership Deed e) Authority letter to sign agreement (if it is not cleared by partnership deed) f) Duly Completed AML Questionnaire g) Duly completed Agent KYC Check list h) Duly completed Certification of Compliance. i) Agent’s Internal AML/CTF Policies & Procedures and controls in place for the prevention of Money Laundering and Terrorist Financing. j) Business Licence required for EU Agents 3) Private Limited Company a) Certificate of Incorporation b) Memorandum & Article of Association c) Board Resolution (only if there are 2 or more directors) d) Govt-Issued Photo identification document of Director(s) and the Witness. Evidence of Authorization to work in the EU must be included. e) Proof of business and personal Addresses (Utility Bill such as BT, Gas, Electricity or Council Tax or Bank Statement) f) Duly Completed information sheet g) Duly Completed AML Questionnaire h) Duly completed Agent KYC Check list i) Duly completed Certification of Compliance j) Agent’s Internal AML/CTF Policies & Procedures and controls in place for the prevention of Money Laundering and Terrorist Financing. k) Business Licence required for EU Agents

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