Anti-Money Laundering Policy

1. Policy Statement

LWorld Venture Sdn. Bhd. is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. We maintain robust policies and procedures to prevent, detect, and report any suspicious activities in accordance with Malaysian laws, including the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA).

2. Know Your Customer (KYC)

All customers must complete our KYC verification process before engaging in transactions. This includes:

• Identity Verification: Valid government-issued identification (NRIC for Malaysians, Passport for non-Malaysians)
• Address Verification: Proof of current residential address (utility bill, bank statement dated within 3 months)
• Source of Funds: Documentation demonstrating the legitimate origin of funds used for transactions
• Purpose of Transaction: Declaration of intended use (investment, gift, collection, etc.)

3. Enhanced Due Diligence

Enhanced due diligence (EDD) measures are applied in higher-risk situations, including:

• High-value transactions exceeding specified thresholds
• Politically Exposed Persons (PEPs) and their associates
• Customers from high-risk jurisdictions
• Complex or unusual transaction patterns
• Corporate or institutional clients

4. Transaction Monitoring

We employ continuous transaction monitoring to identify suspicious activities. Our monitoring systems are designed to detect unusual patterns, including but not limited to: large cash transactions, frequent transactions just below reporting thresholds, transactions inconsistent with customer profile, and rapid movement of assets.

5. Suspicious Activity Reporting

LWorld is obligated to report suspicious transactions to Bank Negara Malaysia and other relevant authorities. We file Suspicious Transaction Reports (STRs) when we have reasonable grounds to suspect that funds may be proceeds of illegal activities or related to terrorist financing. We are prohibited from informing customers when a report has been filed.

6. Cash Transaction Reporting

In compliance with Malaysian regulations, we report all cash transactions above the prescribed threshold (currently RM50,000 or equivalent) to the relevant authorities. This applies to both single transactions and multiple transactions that appear to be linked.

7. Record Keeping

We maintain comprehensive records as required by law, including:

• Customer identification documents and verification records
• Transaction records and supporting documentation
• Correspondence and communication records
• Internal reports and compliance documentation

All records are retained for a minimum of 7 years following the end of the customer relationship or completion of the transaction, whichever is later.

8. Employee Training

All LWorld employees receive regular AML/CTF training to ensure awareness of their obligations and the ability to identify and report suspicious activities. Training covers relevant laws, company policies, red flags, and reporting procedures.

9. Compliance Officer

LWorld has designated a Compliance Officer responsible for overseeing our AML program, ensuring compliance with applicable laws, conducting internal audits, and serving as the primary contact for regulatory authorities.

10. Customer Cooperation

11. Contact

For questions about our AML policy or to report suspicious activities: