Anti-Money Laundering Policy Statement

It is our policy (Nucleus365 Limited) and obligation to comply with the anti-money laundering legal and regulatory requirements, and we take these very seriously. As a registered institution operating in the UK, Nucleus365 Limited is subject to The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“Money Laundering Regulations”); The Terrorism Act 2000; The Proceeds of Crime ("POCA") Act 2002 and The Counter-Terrorism Act 2008.

As it is supervised by the FCA, Nucleus365 Limited is required to meet, among others, the following legal requirements:

• Understand and interpret the legal and regulatory framework for AML/CTF requirements and systems.
• Understand standard industry best practice in AML/CTF procedures and proportionate risk-based approach.
• Design and implement the systems and controls necessary to mitigate the risk of being used in connection with monelaundering or financing terrorism.

Nucleus365 Limited’s AML legal obligations include among others:

• Verify customers’ (including beneficial owners’) identity and address.
• Keep full records of all transactions together with identification provided.
• Monitor any unusual or suspicious transactions of any size.
• Report any suspicious transaction to the National Crime Agency.