🔒 Anti‑Money Laundering (AML) Policy

1. Policy Statement

WilmaNova Limited (“Company”) is committed to complying with all applicable anti‑money laundering and counter‑terrorist financing laws and regulations, including the Hong Kong Anti‑Money Laundering and Counter‑Terrorist Financing Ordinance (Cap. 615) and international best practices. We will not knowingly engage in any transaction that facilitates money laundering, terrorist financing, or other financial crimes.

2. Scope

This policy applies to all directors, employees, consultants, and agents of the Company. It covers all advisory, investment, and transaction‑related activities.

3. Client Due Diligence (CDD)

Before establishing a business relationship or executing a significant transaction, the Company shall:

• Identify and verify the identity of clients (individual or legal entity).
• Identify the beneficial owner(s) of any legal entity client.
• Understand the nature and purpose of the intended business relationship.
• Conduct ongoing monitoring of transactions and update CDD records periodically.

4. Enhanced Due Diligence (EDD)

Enhanced due diligence shall be applied for:

• Politically Exposed Persons (PEPs).
• Clients from high‑risk jurisdictions (as defined by FATF).
• Complex or unusually large transactions without clear economic rationale.

5. Suspicious Activity Reporting

Any employee or consultant who suspects or has reasonable grounds to suspect money laundering or terrorist financing must immediately report the matter to the Company’s AML Compliance Officer. The Company will then file a Suspicious Transaction Report (STR) with the Joint Financial Intelligence Unit (JFIU) of Hong Kong, as required by law.

6. Record Keeping

All CDD records, transaction records, and STRs shall be retained for at least seven (7) years after the termination of the business relationship or completion of the transaction.

7. Training and Awareness

The Company will provide regular AML training to all relevant personnel. Training shall cover identification of red flags, reporting procedures, and regulatory updates.

8. Non‑Compliance

Violation of this policy may result in disciplinary action, termination of engagement, and referral to law enforcement authorities.

9. AML Compliance Officer

Name: Emma Laurent
Email: compliance@wilmanova.com
Direct Line: +852 1234 5678