This document outlines key compliance measures and client relationship policies, specifically tailored for our microfinance operations in The Bahamas, ensuring adherence to local regulations and effective risk mitigation.

1. Compliance

1.1 Money Laundering Reporting Officer (MLRO): In compliance with the Laws of The Bahamas regarding the reporting of suspicious transactions, the Company has appointed a Money Laundering Reporting Officer (MLRO).

1.2 Compliance Officer: To ensure adherence to all relevant regulatory frameworks in The Bahamas, the Company has appointed a Compliance Officer. This individual is responsible for overseeing the Company's compliance with all applicable Bahamian laws.

2. Client Relationships

The Company offers microfinance auto and consumer loans under the Financial and Corporate Service Providers Act. To minimize overall company risk and mitigate Anti-Money Laundering (AML), Counter-Financing of Terrorism (CFT), and Proliferation Financing (PF) risks, the Company has adopted the following policies:

2.1 Acceptance of Payments: The Company may accept payments from clients through the following methods:

• 2.1.1 Cash: Subject to the specific conditions outlined in section 2.2.

• 2.1.2 Wire transfer

• 2.1.3 Cheque

• 2.1.4 Salary deduction from an employer.

2.2 Cash Payment Conditions:

• 2.2.1 Maximum Limit: Cash payments are accepted up to a maximum limit of $3,000.

• 2.2.2 Source of Funds Verification: For any cash amount exceeding $3,000, the client must provide satisfactory documentation verifying the source of funds prior to the Company's acceptance of the payment.

2.3 Disbursement of Funds: The Company does not make cash disbursements to clients under any circumstances. All outgoing payments to clients will be issued via:

• 2.3.1 Wire transfer

• 2.3.2 Cheque

2.4 Return of Funds: If a potential client relationship is not established or a transaction is cancelled, any funds received will be returned only to the original payer. Such refunds will be processed by cheque or wire transfer, consistent with the Company's established disbursement procedures.