AML Policy

1. Policy Statement

Crown Research is committed to the prevention, detection, and reporting of money laundering and terrorist financing. We maintain a robust AML program designed to ensure compliance with all applicable laws and regulations, including the Bank Secrecy Act (BSA) and the USA PATRIOT Act.

2. Customer Due Diligence (CDD)

We apply a risk-based approach to customer due diligence, ensuring that we identify and verify the identity of our customers and assess the potential risks associated with each customer. Our CDD procedures include:

• Verifying the identity of our customers through reliable, independent source documents, data, or information.
• Understanding and, as appropriate, obtaining information on the purpose and intended nature of the business relationship.
• Conducting ongoing monitoring of the business relationship to ensure that the transactions being conducted are consistent with our knowledge of the customer and their risk profile.

3. Suspicious Activity Reporting (SAR)

We are required to report any suspicious transactions or activities that may involve money laundering or terrorist financing. Our employees are trained to identify red flags and report any suspicious activity to our designated AML Compliance Officer for further investigation and, if necessary, reporting to the appropriate authorities.

4. Record Keeping

We maintain all records related to customer identification, account activity, and any reports made to regulatory authorities for a minimum of five years, or as required by applicable law. These records are kept in a manner that allows for timely retrieval and review.

5. Training and Awareness

All employees of Crown Research receive ongoing training to ensure they understand their responsibilities under our AML policy and can identify and report suspicious activities. This training is tailored to the specific roles and responsibilities of our employees and is updated regularly to reflect changes in laws, regulations, and industry best practices.

6. Internal Controls and Audits

We maintain a system of internal controls to ensure ongoing compliance with our AML policy. This includes regular independent audits of our AML program to assess its effectiveness and identify areas for improvement. Any deficiencies identified through these audits are promptly addressed to enhance our AML controls.

7. Risk Assessment

We conduct regular risk assessments to identify and mitigate the risks of money laundering and terrorist financing associated with our business activities. These assessments consider factors such as the types of products and services offered, the types of customers served, and the geographic areas of operation.

8. Sanctions Compliance

We comply with all applicable sanctions programs, including those administered by the Office of Foreign Assets Control (OFAC). Our sanctions compliance program includes screening customers and transactions against relevant sanctions lists and blocking or rejecting transactions that involve sanctioned individuals, entities, or countries.