Counterparty Due Diligence & AML/CTF Policy

Purpose

AVESIRA maintains a risk-based counterparty due diligence framework to protect the integrity of long-term partnerships, safeguard reputation, and reduce exposure to financial crime risk (including money laundering, terrorist financing, sanctions evasion, and related offences).

This policy sets out the information we may request before any partnership is considered and the conditions under which we may decline or discontinue discussions.

Scope

This policy applies to due diligence conducted in connection with:

• Potential counterparties (individuals and entities)
• Ultimate beneficial owners (UBOs) and controlling persons
• Introducers, intermediaries, and referrers
• Special purpose vehicles (SPVs), holding structures, and nominee arrangements
• Partnership structures involving real estate, hospitality, operational platforms, or other assets

Risk-Based Approach

Due diligence requirements vary depending on the risk profile of the proposed partnership. Factors considered may include jurisdiction, asset class, transaction complexity, use of third parties, ownership transparency, and the nature of funding sources.

• Standard review for lower-risk structures with transparent ownership
• Enhanced review where higher-risk indicators are present (e.g., complex ownership chains, high-risk jurisdictions, unusual funding arrangements)

Information We May Request

Depending on the circumstances, AVESIRA may request the following:

• Identity verification for key individuals (directors, signatories, controlling persons)
• Corporate documentation (certificate of incorporation, register extracts, constitutional documents)
• Ownership and control details, including UBO identification and control structure charts
• Business profile (nature of activities, operating history, principal counterparties)
• Sanctions and PEP screening (including politically exposed persons where relevant)
• Source of wealth / source of funds explanations where warranted (e.g., financing origin, capital provenance, supporting documentation)
• Banking / professional references where appropriate (e.g., legal counsel, auditors, regulated institutions)

We may also request clarifications where information is incomplete, inconsistent, or requires validation.

High-Risk Indicators

The following examples may trigger enhanced review or refusal:

• Opaque or undisclosed beneficial ownership
• Use of nominee shareholders/directors without transparent control disclosure
• Unusual urgency, resistance to documentation, or refusal to disclose UBOs
• Funding routes inconsistent with stated profile or commercial rationale
• Jurisdictions subject to heightened sanctions, corruption, or AML risk (as applicable)
• Requests implying “reputational cover” or use of AVESIRA’s presence to legitimise third-party arrangements

Right to Decline or Discontinue

AVESIRA reserves the right, at its sole discretion, to:

• Decline to engage where due diligence requirements are not met
• Pause discussions pending completion of requested information
• Discontinue engagement where risk concerns arise
• Refuse partnerships without providing detailed reasoning where appropriate

Any partnership consideration remains subject to internal approval and formal documentation.

Confidentiality and Data Handling

Information submitted for due diligence is handled under strict confidentiality and used solely for evaluating suitability and risk. Access may be limited to internal reviewers and, where appropriate, professional advisers involved in evaluation.

• We may retain records for a period consistent with operational and legal requirements.
• We may request updated documentation if circumstances change.

Important Clarifications

• This policy is intended to support prudent partnership selection and risk management.
• Nothing on this page constitutes legal advice or creates a client or fiduciary relationship.
• Where required, counterparties may also be subject to independent checks by legal counsel, regulated institutions, or other relevant parties.

Contact

For questions related to counterparty due diligence requirements, please contact: info@avesira.com