Anti-Money Laundering & Counter-Terrorist Financing Policy

1. General Provisions

This Anti-Money Laundering and Counter-Terrorist Financing Policy ("Policy") establishes the principles, systems, and controls implemented by FinUnity PLC to prevent the misuse of its platform for money laundering, terrorist financing, or related financial crimes.

This Policy is adopted in accordance with the Anti-Money Laundering Act, 2012 (as amended), the Anti-Terrorism Act, 2009, circulars and guidelines issued by Bangladesh Bank, and applicable Financial Action Task Force (FATF) recommendations.

2. Scope

This Policy is binding upon all directors, officers, employees, contractors, consultants, and any other persons acting for or on behalf of FinUnity.

3. Nature of Services

FinUnity operates as a business-to-business technology and educational platform. It does not provide regulated financial services, does not hold or transfer client funds, and does not operate payment or settlement accounts.

4. Risk-Based Approach

FinUnity applies a risk-based approach to identify, assess, and mitigate AML/CFT risks proportionate to the nature, scale, and complexity of its activities and partnerships.

5. Due Diligence & Monitoring

Appropriate due diligence measures are applied to business partners and counterparties based on risk. Enhanced scrutiny is applied where elevated risk indicators are identified.

6. Reporting & Cooperation

Any identified suspicious activity is escalated internally. Where legally required, relevant information may be provided to competent authorities, including the Bangladesh Financial Intelligence Unit (BFIU).

7. Sanctions Compliance

FinUnity complies with applicable sanctions regimes implemented by the Government of Bangladesh and the United Nations Security Council.

8. Record Keeping & Review

Compliance-related records are retained in accordance with applicable laws. This Policy is reviewed periodically to reflect legal, regulatory, or risk changes.