Legal Documents

TANGL Capital Partners Ltd AML /STF Policy

Money laundering is defined as the process where the identity of the proceeds of crime are so disguised that it gives the appearance of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firm's knowledge or suspicions.

In response to the scale and effect of money laundering the United Kingdom, in common with many other countries, has passed legislation designed to prevent money laundering and to combat terrorism. This legislation, together with regulations, rules and industry guidance, forms the cornerstone of AML/CTF obligations for UK firms and outline the offences and penalties for failing to comply.

The United Kingdom AML and Regulatory Framework

The UK AML regime is set out in the following legislation and regulations:

• The Proceeds of Crime Act 2002 (POCA), as amended by the:
1. Serious Organised Crime and Police Act 2005 (SOCPA); and the
2. Proceeds of Crime Act (Amendment) Regulations 2007;
• The Terrorism Act 2000, as amended by the:
1. The Anti-Terrorism, Crime & Security Act 2001; and the
2. Terrorism Act (Amendment) Regulations 2007
• The Terrorism Act 2006
• The money Laundering and terrorist financing Regulations 2019
• The Joint Money Laundering Steering Group (JMLSG) Guidance for the UK Financial Sector on the prevention of money laundering/combating terrorist financing.

The TANGL Capital Partners Ltd AML Policy is designed to ensure that all our firms comply with the requirements and obligations set out in the United Kingdom and international legislations, regulations, rules and Industry Guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. The AML Policy sets out the minimum standards which must be complied with by all TANGL Capital Partners Ltd and employees and includes:

• The appointment of a Compliance Officer who has responsibility for the oversight of compliance with relevant legislation, regulations, rules and industry guidance;
• Establishing and using a risk-based approach towards assessing and managing the money laundering and terrorist financing risks to the Group;
• Establishing and maintaining risk-based customer due diligence, identification, verification (ID&V) and know your customer (KYC) procedures, including enhanced due diligence (EDD) for those customers presenting higher risk, such as Politically Exposed Persons (PEPs) and Correspondent Banking relationships;
• Establishing and using a risk-based systems and procedures to monitor ongoing customer activity;
• Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
• The maintenance, storage and back-up of appropriate records for the minimum prescribed periods;
• Continuous training and awareness for all relevant employees;
• And the provision of appropriate management information and reporting to senior management of the Group's compliance with the requirements.

TANGL Capital Partners Ltd Identification and Verification Process

To comply with the relevant Anti-Money Laundering and Counter Terrorist Financing regulations, we require all our clients to provide identification for account verification.

Documents accepted as proof of ID:

• Passport
• Driver's Licenses

All ID documents should display:

• Your full name
• Date of birth
• Your photo
• Date of issuance (within the last 10 years)
• Date of expiry (if applicable)
• All pages should be clear and visible.

Documents accepted as proof of residence:

• Utility bill
• Bank statement
• Government issued letter or notice

Corporate Accounts

Corporate accounts will be subjected to assessment, verification and clearance of the company or partnership as a standalone identity, as well as the assessment, verification and clearance of all directors, shareholders, or partners, including corporate identities, holding more than 25% interest in the registered business. Details that will be used in our assessment and must be submitted include:

TANGL Capital Partners Ltd reserves the right to request, at any point in time, any further documentation and / or verification as required from individual clients where we deem, at our own discretion, or under the instruction of third parties, further investigation is necessary to comply with regulatory obligations.

• A copy of the memorandum and articles of association;
• Latest copy of the most recent accounts;
• Proof of registered address (recent annual return or print out from the company registry);
• Proof of trading (postal) address if different to registered address (recent copy of bill or bank statement showing the company's name and business address);
• Recent bank statement confirming the bank details that will be used to fund the account;
• Copy of register of shareholders or partners as well as verification of the identity of all shareholders and / or partners with a holding of 25% or more;
• Individual shareholders would also need to provide
1. a copy of passport and;
2. a recent copy of residential utility bill being no more than 3 months old.
• Shareholders with a shareholding of 25% or more is corporate entity, then all the above applies to each entity too;
• Identification and address verification of two directors or partners;

Additional Assessment Information required may include:

• Bank account details;
• Employment information
• Source of Fund details
• Cryptocurrency Trading History on recognised Cryptocurrency exchanges

The TANGL Capital Partners Ltd uses electronic identity verification technology provided to us by a leading provider (CREDAS) to verify individuals for age, identity and AML purposes across 27 jurisdictions before our clients are on-boarded and serviced. TANGL Capital Partners Ltd is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. Bitstamp will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.

If you have any questions regarding our AML/STF policy and processes, please do not hesitate to contact us atwww.tanglcapitalpartners.com for more information.