ANTI-MONEY LAUNDERING (AML) & KNOW YOUR CUSTOMER (KYC) POLICY

Effective Date: July 5, 2025

  1. PURPOSE

This document outlines the policies and procedures adopted by WE PLAN INTERNATIONAL TRADE (HK) LTD to prevent its operations from being used to facilitate money laundering, terrorist financing, or other illegal activities. The policy is compliant with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) of Hong Kong and international standards set by the Financial Action Task Force (FATF).

For visitors from the European Economic Area (EEA), we also adhere to the principles of the General Data Protection Regulation (GDPR – EU Regulation 2016/679).

  1. SCOPE

This policy applies to:

  • All business units and subsidiaries of WE PLAN INTERNATIONAL TRADE (HK) LTD
  • All employees, agents, and representatives
  • All customers, suppliers, and third-party partners involved in any form of commercial transaction, including but not limited to commodities (precious metals, agricultural goods, energy products), consulting services, trading of goods, and financial arrangements
  1. CUSTOMER DUE DILIGENCE (CDD)

3.1 Standard CDD Requirements:

  • For Individuals: Valid passport or government-issued ID, proof of address (utility bill or bank statement < 3 months), source of funds declaration
  • For Corporates: Certificate of incorporation, business registration certificate, ownership structure, ID of directors and UBOs, source of funds and purpose of transaction

3.2 Enhanced Due Diligence (EDD):

Applied when customers are:

  • Politically Exposed Persons (PEPs)
  • Based in high-risk jurisdictions
  • Conducting high-volume or unusual transactions

EDD includes:

  • Independent verification of documents
  • Assessment of business background
  • Justification of transaction purpose and economic rationale

3.3 Risk-Based Classification:

A risk matrix is used to classify clients:

Criteria

Low Risk

Medium Risk

High Risk

Country of Origin

HK / OECD

Non-OECD

Sanctioned Countries

Client Type

Listed Company

SME / Trader

Anonymous Individual

Payment Method

Wire Transfer (HKD)

MT103

Cash / Crypto

Transaction Volume

< HKD 100,000

HKD 100k – 1M

> HKD 1M

  1. SANCTIONS & SCREENING

All customers and counterparties are screened against:

  • OFAC, UN, EU, HKMA, and other watchlists
  • Internal blacklist database Screening is performed prior to onboarding and refreshed periodically.
  1. RECORD KEEPING

All documents and transaction records are kept for a minimum of 7 years. Records include:

  • KYC documents
  • Invoices and contracts
  • Payment proofs
  • Shipping and customs documents
  • Internal screening reports
  1. TRANSACTION MONITORING

The company maintains:

  • Ongoing monitoring of customer transactions
  • Alerts for large, unusual, or suspicious activities
  • Monthly compliance reviews for active accounts

A Suspicious Activity Register is maintained:

  • Date
  • Client
  • Nature of alert
  • Actions taken

Final decision

  1. CASH TRANSACTIONS

WE PLAN INTERNATIONAL TRADE (HK) LTD does not accept or make any payments in cash. All transactions must be processed through traceable banking channels

  1. SUPPLY CHAIN DUE DILIGENCE

The company only sources goods and services from verified suppliers. For commodities or high-value goods, required documents include:

  • Certificate of Origin
  • Export permit or relevant licenses
  • Third-party inspection (SGS or equivalent)
  • Declaration of legal and ethical sourcing where applicable
  1. COMPLIANCE OFFICER

A Compliance Officer is appointed to:

  • Supervise implementation of the AML/KYC policy
  • Train staff annually on AML obligations
  • Review and approve new client onboarding
  • Report any suspicious transactions to the C&ED (HK Customs)
  1. TRAINING

All relevant employees must undergo annual AML training. New staff must receive training during onboarding. Records of training sessions will be retained for compliance purposes.

  1. REVIEW & UPDATE

This policy is reviewed at least annually and updated to reflect changes in regulation, business structure, or operational exposure.

Approved by:  Mr. MACOUANGOU NZABA Y.
Position: President
Date: July 2025