AML/CFT Policy

The framework we operate under

Kent Investments Ltd is licensed by the Financial Services Commission (FSC) of Mauritius as an Investment Dealer, licence GB24202944, and is a reporting person under Mauritian anti-money-laundering law.

Mauritius is a founder member of the Eastern and Southern Africa Anti-Money Laundering Group, an associate member of the Financial Action Task Force, and committed to the FATF's 40 Recommendations in 1997. The principal domestic legislation is the Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA), together with the Financial Crimes Commission Act 2023, which established the Financial Crimes Commission as the apex agency for detecting, investigating and prosecuting financial crime and which repealed and replaced parts of the earlier framework.

The framework was extended in 2018 to cover the financing of proliferation and to give AML/CFT supervisors powers to supervise and enforce compliance.

A risk-based approach

The Company assesses money-laundering and terrorist-financing risk across four pillars, and the assessment determines how much diligence a relationship attracts:

• •Customer risk — the type of client, the business rationale for the relationship, and the source of funds and source of wealth.
• •Product risk — the money-laundering and terrorist-financing risk carried by the instruments offered, recognising that some products can be misused because of their complexity.
• •Interface risk — how the Company deals with the client. Risk rises where contact is less direct: remote or online-only onboarding without face-to-face verification, or third-party introductions without robust verification.
• •Geographic risk — the client's country of residence and of operation.

Customer due diligence

The Company identifies and verifies every client before a relationship begins, and identifies beneficial owners behind legal persons and legal arrangements. The evidence required differs for natural persons, legal persons and legal arrangements, and is set out in full in the manual.

Knowingly providing false or misleading information to a reporting person in connection with customer due diligence is an offence under the FIAMLA, carrying a fine and a term of imprisonment on conviction.

Reporting and record keeping

Suspicious transactions are reported as the FIAMLA requires. Every member of staff is made aware of the reporting chain and the procedure to follow if suspicious activity is discovered, and staff confirm in writing that they have read and understood their obligations — on joining, and again after any material change to the manual.

The manual is provided to employees, who are required to be fully aware of its contents.

Responsibility

The Company appoints a Money Laundering Reporting Officer, with a Deputy, as required by the FSC's AML/CFT Handbook, and maintains written internal policies, procedures and controls.