Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy

ALPHA ESTABLISHMENT PTY LTD
Effective Date: October 08, 2025

1. Introduction

This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy (“Policy”) outlines the commitment of ALPHA ESTABLISHMENT PTY LTD (“the Company”) to comply with all applicable AML/CTF laws and regulations in the jurisdictions in which it operates.

As a provider of digital cards and related online products, the Company acknowledges the potential risk of misuse of its services for money laundering, terrorist financing, and other illicit purposes. The purpose of this Policy is to establish internal controls, procedures, and responsibilities to prevent such misuse and to safeguard the integrity of the Company’s operations.

2. Regulatory Compliance

The Company commits to full compliance with:

• Australia’s Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act)
• Rules and guidance issued by AUSTRAC (Australian Transaction Reports and Analysis Centre)
• Relevant international standards, including the Financial Action Task Force (FATF) Recommendations

3. Governance and Oversight

The Board of Directors of ALPHA ESTABLISHMENT PTY LTD has ultimate responsibility for the implementation of this Policy. A designated AML Compliance Officer has been appointed with authority to oversee daily compliance operations, including monitoring, training, and reporting.

4. Customer Due Diligence (CDD) and Know Your Customer (KYC)

The Company adopts a risk-based approach to customer verification:

• Standard CDD: For all customers, collection and verification of basic identification information (full name, date of birth, email, payment details).
• Enhanced Due Diligence (EDD): Required for high-risk customers, jurisdictions, or transactions exceeding material thresholds. This includes government-issued photo identification, proof of address, and additional risk assessments.
• Ongoing Monitoring: Continuous monitoring of customer activity to ensure transactions align with known business and personal profiles.

5. Monitoring and Reporting of Suspicious Activity

The Company has established systems and procedures to detect, investigate, and report suspicious activities, including but not limited to:

• Unusually large or structured transactions.
• Multiple transactions designed to avoid reporting thresholds.
• Use of fraudulent or stolen payment instruments.
• Transactions inconsistent with a customer’s known profile.

Where suspicious activity is identified, a Suspicious Matter Report (SMR) will be promptly filed with AUSTRAC in accordance with the AML/CTF Act.

6. Record-Keeping

The Company will retain the following for a minimum of seven (7) years or as required by law:

• Customer identification records.
• Transaction records.
• Internal AML/CTF compliance records and reports.

7. Employee Training

The Company provides mandatory AML/CTF training to all relevant employees on:

• Applicable AML/CTF obligations.
• CDD and EDD procedures.
• Identifying and escalating suspicious activity.
• Record-keeping and reporting obligations.

Training will be conducted at onboarding and refreshed annually.

8. Independent Review

The AML/CTF framework will be subject to independent audit or review on a regular basis to ensure effectiveness and ongoing compliance with applicable regulations.

9. Policy Review

This Policy will be reviewed at least annually or sooner if required due to changes in legislation, regulatory guidance, or the Company’s risk profile.