AML POLICY (ANTI-MONEY LAUNDERING)

Purpose

Establish procedures designed to prevent money laundering, terrorist financing, fraud, sanctions violations, and illicit financial activity.

Key Sections

Customer Due Diligence (CDD)

Client identification
Corporate verification
Beneficial ownership review
Source of funds verification

Enhanced Due Diligence (EDD)

Required for:

High-risk jurisdictions
PEPs (Politically Exposed Persons)
Large transactions
Complex ownership structures

Sanctions Screening

OFAC screening
UN sanctions screening
EU sanctions screening
UK sanctions screening

Suspicious Activity Review

Unusual transaction patterns
Inconsistent source of funds
False documentation
Adverse media findings

Ongoing Monitoring

Transaction reviews
Periodic client updates
Compliance reassessments

KYC POLICY (KNOW YOUR CUSTOMER)

Client Verification Requirements

Individuals

Government-issued ID
Proof of address
Source of wealth
Source of funds

Corporate Clients

Articles of Incorporation
Certificate of Good Standing
Operating Agreement
Corporate Resolution
Beneficial Ownership Declaration

Required Reviews

Identity verification
Business purpose verification
Transaction purpose verification
Risk classification

Risk Categories

Low Risk
Moderate Risk
High Risk
Enhanced Review

PRIVACY POLICY

Information Collected

Name
Email
Phone
Corporate information
Project information
Financial documentation

Use of Information

Due diligence
Compliance review
Project evaluation
Client communications

Data Protection

Encryption
Secure storage
Restricted access
Data retention controls

Third Party Sharing

Only when:

Required by law
Compliance review
Banking institutions
Professional advisors

TERMS & CONDITIONS

Website Use

Informational purposes only
No banking relationship created
No investment advice provided

Intellectual Property

Website content protected
Trade secrets protected
Proprietary information protected

Limitation of Liability

No guarantee of funding
No guarantee of approval
No guarantee of monetization

Governing Law

Applicable jurisdiction within the Cayman Islands and venue.

RISK DISCLOSURE

Important Notice

All structured finance transactions involve risk.

Risks Include

Market risk
Regulatory risk
Counterparty risk
Compliance risk
Transaction risk

No Guarantees

Visions Capital Holdings does not guarantee:

Funding
Returns
Monetization
Issuance
Acceptance
Investor participation

Independent Advisors

Clients should consult legal, tax, accounting, and financial advisors.

CLIENT SUITABILITY STANDARDS

Qualified Clients

Infrastructure developers
Humanitarian organizations
Corporations
Institutional investors
Family offices
Funds
Sovereign entities

Transaction Requirements

Legitimate business purpose
Verifiable source of funds
Compliance approval
Project feasibility

Non-Qualified Activities

Consumer lending
Retail investments
Unverified transactions
Sanctioned activities
Fraudulent activities

COMPLIANCE FRAMEWORK

Core Components

AML Compliance

KYC Compliance

Sanctions Compliance

Fraud Prevention

Beneficial Ownership Review

Source of Funds Verification

Source of Wealth Verification

Compliance Process

Client Intake
Document Collection
KYC Verification
AML Screening
Risk Assessment
Underwriting Review
Compliance Approval
Transaction Structuring

DOCUMENT RETENTION POLICY

Retention Periods

Client Files

Minimum 7 Years

Compliance Records

Minimum 7 Years

Transaction Documents

Minimum 7 Years

Communications

Minimum 5 Years

Storage Standards

Secure servers
Access controls
Encryption
Audit trails

CORPORATE GOVERNANCE STATEMENT

Governance Principles

Integrity

Commitment to ethical business practices.

Transparency

Accurate disclosure and reporting.

Accountability

Defined responsibilities and oversight.

Compliance

Adherence to applicable laws and regulations.

Risk Management

Ongoing assessment and mitigation of risk.

DOCUMENT RETENTION POLICY

Core Components

AML Compliance

KYC Compliance

Sanctions Compliance

Fraud Prevention

Beneficial Ownership Review

Source of Funds Verification

Source of Wealth Verification

Compliance Process

Client Intake
Document Collection
KYC Verification
AML Screening
Risk Assessment
Underwriting Review
Compliance Approval
Transaction Structuring

Private / Confidential / Proprietary / NDA / Trade Secrets

Visions Capital Holdings is a private desk in financial solutions and project finance advisory board. Visions Capital Holdings is not a bank, deposit-taking institution, broker-dealer, investment advisor, or licensed financial institution unless otherwise disclosed in writing. All transactions remain subject to independent due diligence, underwriting review, compliance approval, institutional acceptance, and applicable regulatory requirements. No guarantee of funding, monetization, issuance, returns, or transaction approval is expressed or implied.