Kinetic’s Anti-Money Laundering, Countering Financing of Terrorism, Countering Proliferation Financing, and Targeted Financial Sanctions Policy Statement

Kinetic DAX Sdn. Bhd. (“Kinetic” or “the Company”) affirms its commitment to managing the threats of money laundering, countering the financing of terrorism, countering proliferation financing, and implementing targeted financial sanctions. The Company is dedicated to safeguarding the integrity of its financial services and protecting the interests of its customers, stakeholders, and employees. Kinetic adopts a proactive and responsible approach through its Anti-Money Laundering, Countering Financing of Terrorism, Countering Proliferation Financing, and Targeted Financial Sanctions (“AML/CFT/CPF and TFS”) Programme (“the Programme”), as outlined in its AML/CFT/CPF and TFS Policy (“the Policy”). The Policy underscores the Company’s commitment to comply with laws and regulations issued or published by the regulatory bodies and authorities to eliminate illicit activities.

AML/CFT/CPF and TFS Programme Framework

The Company adopts a risk-based approach in implementing its policies, procedures, processes, systems, and controls in line with regulatory expectations. This includes:

• Establishing roles and responsibilities of the Board of Directors, Board Audit, Risk and Compliance Committee, Senior Management, Compliance Officer and all employees with regard to AML/CFT/CPF and TFS to denote clear accountability at all levels;
• Conducting periodic AML/CFT/CPF and TFS risk assessments to determine Kinetic’s risk landscape and evaluate the effectiveness of corresponding controls;
• Enacting a robust Know-Your-Customer process that enables the Company to undertake a consistent Customer Due Diligence approach, risk rating customers based on their profiles, and adherence to the wire transfer rule;
• Detecting suspicious activities supplemented with transaction monitoring and periodic reviews of customers’ transactions and profiles;
• Highlighting and enforcing TFS regimes applicable to Kinetic through screening new, potential, and existing customers, and maintaining an up-to-date database on applicable regimes;
• Timely and accurate reporting of suspicious transactions, activities, and any relevant sanctions concerns, including active collaboration with regulators and law enforcement agencies in investigations; and
• Implementing robust internal audit, compliance review processes, training and communication and retention of records to ensure the effectiveness of the AML/CFT/CPF and TFS Programme and adherence to regulatory requirements.