MESSIAH AML/CFT Policies

MESSIAHS,

Please ensure you read MESSIAH's Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Policies carefully. This document outlines the policies and procedures for Messiah Holdings Limited. This document is intended for general informational purposes only and is not legally binding on MESSIAH and/or any other person (natural or otherwise).

 

A. Principles and Methods of MESSIAH AML/CFT Measures

MESSIAH is committed to supporting AML/CFT efforts. In principle, we are committed to:

• Conducting due diligence when dealing with our customers and natural persons appointed to act on behalf of our customers.

• Conducting business by high ethical standards and, to the greatest extent possible, preventing the establishment of any business relationship that is related to or could contribute to money laundering or terrorism financing.

• Assisting and cooperating with the relevant legal authorities, to the fullest extent possible, to prevent the threat of money laundering and terrorism financing.

B. MESSIAH's Risk Assessment and Risk Mitigation Methodology

Risk Assessment We anticipate that the majority of our customers will be retail customers. As of the date of this policy, we are an Exempted Company incorporated in the Cayman Islands with Limited Liability.

 

In this regard, we shall:

1. Record and/or collect documentation on the following:

   • The identity of our customers.

   • The country or jurisdiction from or in which our customers are located.

2. Screen customers and beneficial owners against designated lists including, but not limited to:

   • Democratic People's Republic of Korea, Iran, Libya, Somalia, South Sudan, Sudan, Yemen.

   • UN Al Qaida (1267/1989) and UN Taliban (1988) sanctions lists.

   • Persons identified in Schedule 1 of the Terrorism (Suppression of Financing) Act.

Risk Mitigation

When identified, we shall not deal with anyone on the list of designated individuals and entities.

C. New Products, Practices, and Technical Methodology

We shall assess money laundering and terrorist financing risks arising from the development of new products, business practices, and the use of new or developing technologies. We pay particular attention to products that facilitate anonymity, such as certain digital passes or tokens.

D. Approach to Customer Due Diligence (CDD)

• No Anonymity: We do not open, maintain, or accept anonymous or pseudonymous accounts.

• Criminal Proceeds: We shall not enter into a business relationship if we suspect funds are proceeds of criminal behavior. We shall file a Suspicious Transaction Report (STR) where necessary.

• Verification: We verify the identity of all customers. Required info includes: Full name (and aliases), unique identification number (e.g., passport or business registration number), registered address, date of birth/incorporation, and nationality.

E. Enhanced Customer Due Diligence (EDD)

• Politically Exposed Persons (PEPs): For customers identified as PEPs or their close associates, we require senior management approval, establishment of the source of wealth/funds, and enhanced ongoing monitoring.

• High-Risk Jurisdictions: We perform enhanced CDD for customers from jurisdictions for which the FATF has called for countermeasures or identified as having inadequate AML/CFT measures.

F. Restriction of Cash and Bearer Instruments

• We shall not make any payment in the form of a bearer negotiable instrument.

• We shall not pay any cash in any amount in the course of carrying on our business.

G. Value Transfer (Travel Rule)

Before executing a value transfer, we shall identify the originator and beneficiary. For transfers exceeding specific thresholds, we will ensure the originator’s identity and address/ID information are securely submitted to the beneficiary institution.

H. Record Keeping

We shall retain all CDD data, documents, and transaction records for at least 5 years.

I. Compliance, Audit, and Training

We shall appoint an AML/CFT Compliance Officer at the management level, maintain independent audit capabilities, and conduct regular employee training on AML/CFT matters.

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