Anti-Money Laundering (AML) Policy

XRT Group LLC is committed to the highest standards of Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and international sanctions compliance across all its global operations.

1. Policy Statement

XRT Group LLC (“XRT,” “we,” “us,” or “our”) maintains a comprehensive Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) compliance program designed to prevent, detect, and report any attempts to use our trade infrastructure, financial channels, or commercial relationships for money laundering, terrorist financing, sanctions evasion, or other illicit financial activities.

This AML Policy applies to all directors, officers, employees, contractors, agents, and business partners of XRT worldwide. Compliance with this Policy is mandatory and non-negotiable.

2. Regulatory Framework

Our AML/CTF program is structured to comply with the following international and domestic regulatory frameworks:

• FATF Recommendations — The 40 Recommendations of the Financial Action Task Force (FATF), the global standard-setter for AML/CTF, as amended from time to time.
• USA Patriot Act & Bank Secrecy Act (BSA) — US federal legislation requiring financial institutions and certain businesses to establish AML programs, file Suspicious Activity Reports (SARs), and maintain appropriate records.
• EU Anti-Money Laundering Directives (AMLD) — Including the 5th AMLD (Directive 2018/843) and the 6th AMLD (Directive 2018/1673) applicable to our Rotterdam hub operations.
• OFAC Regulations — US Office of Foreign Assets Control sanctions programs and the Specially Designated Nationals and Blocked Persons List (SDN List).
• UK Money Laundering Regulations (MLR 2017) — As amended, applicable to transactions involving UK counterparties or financial institutions.
• Singapore MAS Notices — Monetary Authority of Singapore AML/CFT Notices applicable to our Singapore hub operations under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (CDSA) and the Terrorism (Suppression of Financing) Act (TSOFA).

3. Risk-Based Approach

XRT employs a risk-based approach (RBA) to AML/CTF compliance, consistent with FATF Recommendation 1. This means we identify, assess, and understand the money laundering and terrorist financing risks to which we are exposed, and implement controls proportionate to those risks.

3.1 Risk Factors Assessed

For every new and existing counterparty, transaction, and trade corridor, we assess:

• Geographic risk: Country of origin, destination, and transit for goods and funds, with heightened scrutiny for FATF high-risk jurisdictions, OFAC-sanctioned countries, and jurisdictions with identified strategic AML deficiencies.
• Counterparty risk: Ownership structure, ultimate beneficial ownership (UBO), politically exposed person (PEP) status, adverse media screening, and industry reputation.
• Transaction risk: Transaction value, complexity, payment methods, unusual routing, involvement of third-party intermediaries or shell companies, and transactions inconsistent with the counterparty's known business profile.
• Commodity risk: Vulnerability of specific commodities to trade-based money laundering (TBML), including over/under-invoicing, phantom shipments, and document fraud.

3.2 Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied when higher-risk factors are identified, including but not limited to:

• Counterparties in or connected to high-risk jurisdictions
• Politically Exposed Persons (PEPs) and their close associates or family members
• Complex or opaque ownership structures involving multiple jurisdictions or bearer shares
• Transactions with unusual pricing, volumes, routing, or documentation patterns
• Cash-intensive businesses and industries
• Counterparties subject to adverse media or regulatory actions

EDD measures include enhanced documentation requirements, senior management approval for onboarding and transactions, independent verification of UBO information, source of funds/wealth inquiries, and ongoing monitoring.

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

XRT conducts thorough Customer Due Diligence (CDD) on all counterparties before establishing a business relationship and on an ongoing basis thereafter. Our CDD process includes:

1. Identification & verification: Collecting and verifying the identity of the counterparty using reliable, independent source documents, data, or information. For legal entities, this includes verifying the legal status, ownership structure, and business registration.
2. Ultimate Beneficial Ownership (UBO): Identifying and verifying the natural person(s) who ultimately own or control 25% or more of the shares or voting rights of a legal entity, or who otherwise exercise effective control.
3. Nature and purpose of the business relationship: Understanding the counterparty's business activities, expected transaction volumes, trade corridors, and source of funds.
4. Sanctions & PEP screening: Screening all counterparties, UBOs, directors, and authorized signatories against applicable sanctions lists, PEP databases, and adverse media sources using recognized screening tools and databases.
5. Ongoing monitoring: Periodic review of CDD information, transaction activity monitoring, and re-screening against updated sanctions and PEP lists.

XRT maintains complete and accurate CDD records for a minimum of 5 years after the business relationship ends, or longer if required by applicable law.

5. Trade-Based Money Laundering (TBML) Controls

Given the nature of XRT's business in international commodity trading, we are acutely aware of the risks of Trade-Based Money Laundering (TBML) and maintain specific controls to prevent and detect TBML schemes, including:

• Invoice verification: Systematic review of commercial invoices, bills of lading, certificates of origin, inspection certificates, and other trade documentation for consistency and authenticity.
• Pricing analysis: Comparison of declared commodity values against prevailing international market prices, industry benchmarks, and Platts/ICE assessments to detect over- or under-invoicing.
• Quantity and weight verification: Reconciliation of declared quantities with independent inspection reports and shipping documentation.
• Sanctions checks on trade routes: Verification that vessels, shipping companies, ports, and transit routes are not subject to sanctions or used for illicit purposes.
• Dual-use goods screening: Ensuring that commodities traded are not diverted for prohibited end-uses, military applications, or to sanctioned entities.
• Document integrity: Verification of the authenticity and consistency of trade documents, including cross-referencing with independent certification bodies and government agencies where applicable.

6. Suspicious Activity Reporting

XRT has clear procedures for identifying and reporting suspicious activities. All personnel are trained to recognize red flags and to escalate concerns promptly.

6.1 Red Flags

Indicators of potential money laundering, terrorist financing, or sanctions evasion include:

• Reluctance or refusal to provide complete KYC documentation or UBO information
• Transactions involving shell companies, bearer share entities, or opaque offshore structures
• Requests to route payments through unrelated third parties or jurisdictions
• Inconsistent or illogical trade routes, shipping patterns, or commodity types relative to the counterparty's stated business
• Significant discrepancies between declared values and market prices
• Cash or cryptocurrency payment requests in transactions typically settled through banking channels
• Unusually complex transaction structures with no apparent commercial rationale
• Counterparty or UBO appearing on sanctions, PEP, or adverse media lists
• Attempts to structure transactions to avoid reporting thresholds
• Pressure to expedite transactions without normal due diligence

6.2 Reporting Obligations

When suspicious activity is identified, XRT shall, where legally required or appropriate:

• File Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs) with the relevant national Financial Intelligence Unit (FIU) in the applicable jurisdiction (e.g., FinCEN in the US, FIU-Nederland in the Netherlands, STRO in Singapore).
• Maintain confidentiality regarding the existence and content of any SAR/STR filing (prohibition on “tipping off”).
• Cooperate fully with law enforcement and regulatory authorities in any investigation arising from a SAR/STR.

7. Training & Awareness

XRT provides regular, mandatory AML/CTF training to all relevant personnel, including:

• New-hire AML induction training within 30 days of joining
• Annual refresher training for all personnel involved in commercial, finance, compliance, and logistics functions
• Role-specific training for personnel in high-risk functions (e.g., trade finance, commodity desk, compliance)
• Updates on emerging AML/CTF risks, regulatory changes, and typologies

Training records are maintained and reviewed as part of the compliance monitoring program.

8. Record Keeping

XRT maintains comprehensive records of all AML/CTF compliance activities, including:

• CDD/EDD documentation for all counterparties
• Sanctions and PEP screening results
• Transaction records including trade documentation
• Suspicious activity assessments and SAR/STR filings
• Training records
• Internal and external audit reports

All records are maintained for a minimum of 5 years after the business relationship ends or the transaction is completed, or longer if required by applicable law.

9. Compliance Oversight & Audit

XRT's AML/CTF compliance program is overseen by the Compliance Officer, who reports directly to senior management. The Compliance Officer is responsible for:

• Developing, implementing, and maintaining AML/CTF policies and procedures
• Ensuring regulatory filings (SARs/STRs) are made in a timely manner
• Conducting periodic risk assessments
• Overseeing training programs
• Responding to regulatory inquiries and examinations
• Reporting to senior management on the effectiveness of the AML/CTF program

XRT conducts an independent audit of its AML/CTF program annually (or more frequently if warranted by risk assessment) to evaluate the effectiveness of controls and identify areas for improvement.

10. Non-Compliance

Violations of this AML Policy may result in disciplinary action, up to and including termination of employment or business relationship, and may expose the individual and the company to civil and criminal penalties. XRT has a zero-tolerance approach to money laundering, terrorist financing, and sanctions evasion.

Contact

For questions about this AML Policy, to report concerns, or to request additional information:

© 2026 XRT Group LLC. This AML Policy is reviewed and updated at least annually to reflect changes in applicable laws, regulations, FATF recommendations, and evolving money laundering/terrorist financing risks.