AML/CFT Statement

1. Introduction and Commitment

Phoenix Investment Bank (Labuan) Ltd. ("Phoenix" or "PIBL") is firmly committed to preventing its services, products, and infrastructure from being used as a vehicle for money laundering, terrorist financing, proliferation financing, or any other form of financial crime.

This AML/CFT Statement outlines the principles, obligations, and procedures that Phoenix adopts to detect, prevent, and report suspicious financial activity. This Statement applies to all clients, counterparties, business partners, and transactions associated with Phoenix.

2. Regulatory Framework

Phoenix's AML/CFT compliance framework is anchored in the following regulatory requirements and international standards:

• Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA), Malaysia
• Labuan Financial Services and Securities Act (LFSSA) 2010
• Guidelines on Anti-Money Laundering, Countering Financing of Terrorism, Countering Proliferation Financing and Targeted Financial Sanctions for Labuan Key Reporting Institutions (AML/CFT/CPF and TFS for Labuan KRIs).
• Financial Action Task Force (FATF) Recommendations — the global standard for AML/CFT
• United Nations Security Council Resolutions relating to terrorist financing and proliferation

Phoenix's compliance program is reviewed and updated regularly to reflect changes in the regulatory landscape and emerging financial crime typologies.

3. Client Due Diligence (CDD)

Prior to establishing any business relationship or executing any transaction, Phoenix conducts comprehensive Client Due Diligence in accordance with a risk-based approach. CDD measures include:

3.1 Standard CDD

• Verification of client identity using reliable, independent documentary sources (government-issued identification, company registration documents, or equivalent);
• Identification and verification of beneficial owners, including natural persons and also person exercising ultimate ownership or effective control over a legal entity, in accordance with applicable AML/CFT requirements.
• Understanding the nature and purpose of the business relationship;
• Assessment of source of funds and source of wealth;
• Screening against international sanctions lists and Politically Exposed Persons (PEP) databases.

3.2 Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied to higher-risk clients, relationships, and transactions, including:

• Politically Exposed Persons (PEPs) and their close associates or family members;
• Clients or transactions from high-risk jurisdictions as identified by FATF;
• Clients with complex ownership structures or opaque beneficial ownership;
• High-value transactions that are inconsistent with the client's known profile;
• Transactions involving correspondent banking relationships with higher-risk institutions.

3.3 Simplified CDD

Simplified CDD measures may be applied in limited circumstances where the risk of money laundering or terrorist financing is assessed to be low, subject to Labuan FSA guidance and Phoenix's internal risk policy.

4. Ongoing Monitoring

Phoenix conducts ongoing monitoring of all business relationships and transactions to ensure consistency with the client's known profile, business activities, and risk classification. This includes:

• Transaction monitoring for unusual patterns, structuring, or activity inconsistent with the client's declared profile;
• Periodic review and refresh of KYC documentation and client risk assessments;
• Monitoring of changes in client circumstances, beneficial ownership, or jurisdictional risk;
• Screening of transactions against updated sanctions and watchlists on an ongoing basis.

5. Suspicious Transaction Reporting

Phoenix is legally obligated to report any transaction or activity that raises reasonable suspicion of money laundering, terrorist financing, or other financial crime to the relevant competent authorities, including the Financial Intelligence and Enforcement Department (FIED) of Bank Negara Malaysia, as required under AMLA and Labuan FSA regulations.

Phoenix operates a strict "tipping off" prohibition. Phoenix is prohibited by law from disclosing to a client or any third party that a suspicious transaction report has been filed or that an investigation is underway in respect of that client or transaction.

6. Record Keeping

Phoenix maintains comprehensive records of all client identification data, transaction records, and CDD documentation for a minimum of six (6) years from the date of the transaction or the date of termination of the business relationship, whichever is later, in accordance with AMLA and Labuan FSA requirements.

7. Employee Training and Culture

All Phoenix personnel are required to complete AML/CFT training appropriate to their role and level of responsibility. Training covers applicable laws and regulations, Phoenix's internal AML/CFT policies, recognition of red flags and suspicious activity, and mandatory reporting obligations.

Phoenix maintains a culture of compliance in which all personnel are expected to take responsibility for AML/CFT risk management within their area of activity and to escalate any concerns promptly to the designated Compliance Officer.

8. Risk-Based Approach

Phoenix applies a risk-based approach (RBA) to AML/CFT, calibrating the intensity of due diligence, monitoring, and controls to the level of money laundering and terrorist financing risk associated with each client, product, service, delivery channel, and geographic exposure. Risk assessments are reviewed periodically and updated in response to emerging threats and regulatory guidance.

9. Sanctions Screening

All clients, counterparties, transactions, and related parties are screened against applicable sanctions and watchlists, including the Domestic List issued by the Ministry of Home Affairs of Malaysia (MOHA), the United Nations Security Council Resolutions (UNSCR) Lists, the Office of Foreign Assets Control (OFAC) of the United States, the European Union Consolidated Sanctions List, the United Kingdom Office of Financial Sanctions Implementation (OFSI) List, and other relevant sanctions, regulatory, and law enforcement lists, as applicable. Phoenix will not knowingly engage in any transaction that would violate applicable sanctions laws, regulations, or targeted financial sanctions requirements.

10. Compliance Officer

Phoenix has appointed a designated Compliance Officer responsible for the oversight, implementation, and maintenance of Phoenix's AML/CFT compliance program. Any AML/CFT concerns or queries may be directed to the Compliance Officer via: