Anti-money laundering
& CFT policy.

01Purpose and scope

Sherview Services Group (“Sherview”, “we”) is committed to preventing money laundering, the financing of terrorism and the financing of the proliferation of weapons of mass destruction (together, “financial crime”). This policy sets out how we meet that commitment.

It applies to every Sherview entity, office (United States, Panama City and the GCC), partner, employee, contractor and introducer, and to every service we provide: corporate formation and structuring, tax planning, Panama offshore and banking support, legal support, residency and relocation, and IT.

02Legal and regulatory framework

We comply with all applicable laws and regulations, in particular those of the Republic of Panama, including:

• Law 23 of 27 April 2015, which adopts measures to prevent money laundering, the financing of terrorism and the financing of the proliferation of weapons of mass destruction, as amended (including by Law 254 of 11 November 2021);
• Executive Decree 35 of 2022, which regulates Law 23 of 2015;
• Law 129 of 17 March 2020, which created the private and unified registry of beneficial owners, and its regulations;
• Law 81 of 26 March 2019 on personal data protection;
• the guidance and resolutions of the Superintendencia de Sujetos No Financieros and the Unidad de Análisis Financiero (UAF).

We also apply the rules of the other jurisdictions where we operate, including:

• in the United Arab Emirates, Federal Decree-Law No. 10 of 2025 on anti-money laundering and combating the financing of terrorism and proliferation, and its executive regulations;
• in the United States, economic sanctions administered by the Office of Foreign Assets Control (OFAC) and, where applicable, the Bank Secrecy Act;
• the FATF Recommendations and the sanctions regimes of the United Nations Security Council, the European Union and the United Kingdom.

Where these requirements differ, we apply the stricter standard.

03Governance

A designated Compliance Officer is responsible for this policy, for our risk assessment, for client-acceptance decisions on higher-risk matters and for liaison with supervisors and the UAF. The Compliance Officer reports directly to senior management and has the authority and resources to do so independently.

Senior management approves this policy and reviews it at least once a year, or sooner when laws, our services or our risks change. Our controls are subject to periodic independent review.

04Risk-based approach

We identify, assess and document the financial-crime risks of our business, as required by Article 26 of Law 23 of 2015 as amended, and apply controls in proportion to them. Each client receives a risk rating based on factors including:

• the client’s and beneficial owners’ countries of residence, nationality and activity;
• politically exposed person (PEP) status, adverse media and sanctions exposure;
• the nature of the business, including digital-asset, tokenization, cash-intensive or high-value-goods activity;
• the complexity and opacity of the ownership structure;
• the services requested, the delivery channel and the expected flows of funds.

05Client due diligence

Before we provide any service, and with no exceptions, we:

• verify the identity of the client and of every person acting on its behalf, using reliable, independent documents and data;
• identify and verify each beneficial owner, meaning every natural person who ultimately owns or controls the client, applying the lowest ownership threshold required by applicable law;
• understand the purpose and intended nature of the relationship;
• establish the source of funds for the engagement and, where the risk requires, the source of wealth;
• screen all parties against sanctions lists, PEP databases and adverse media.

Our onboarding is fully digital. Identity documents are verified electronically and matched to the holder with a biometric liveness check, which mitigates the risks of non-face-to-face onboarding. Where verification can’t be completed digitally, we use certified documents or a video verification call.

Our onboarding threshold is a net worth of at least US$200,000. Meeting it never replaces due diligence.

06Enhanced due diligence

We apply enhanced measures to higher-risk clients, including PEPs and their family members and close associates, clients connected with jurisdictions identified by the FATF as high-risk or under increased monitoring, and complex or unusual structures. Enhanced measures include:

• senior-management approval before accepting or continuing the relationship;
• corroborated evidence of source of wealth and source of funds;
• more frequent and more detailed ongoing monitoring.

07Digital-asset clients

Because we serve digital-asset and tokenization businesses, we additionally:

• review whether the client holds the licences or registrations its activity requires;
• screen relevant wallet addresses with blockchain-analytics tools and assess exposure to sanctioned, illicit or high-risk sources;
• trace the origin of crypto-asset wealth used to fund engagements or structures, including exchange records and on-chain history.

08Relationships we do not accept

• persons or entities subject to applicable sanctions, or owned or controlled by them;
• shell banks, and anyone seeking anonymity or acting through nominees to conceal ownership;
• structures using bearer shares or other instruments that hide beneficial ownership;
• clients who decline to provide due-diligence information, or whose information we can’t verify;
• activity we believe is intended to evade tax, sanctions or the law.

09Ongoing monitoring

We monitor relationships throughout their life, screen clients against sanctions lists on an ongoing basis, and refresh due diligence periodically according to risk rating, and whenever we learn of a material change in ownership, activity or risk.

10Suspicious activity reporting

Staff must escalate any knowledge or suspicion of financial crime to the Compliance Officer immediately. Where required, we file a suspicious-operation report with Panama’s UAF in accordance with Article 54 of Law 23 of 2015, or with the competent authority in the relevant jurisdiction, within the timeframes the law sets.

Consistent with Article 56 of Law 23 of 2015, we do not disclose to clients or third parties that a report has been made or that information has been requested. We may decline, suspend or end any engagement where we have concerns.

11Record keeping

We keep due-diligence records, engagement records and transaction documentation for at least five years after a relationship ends, or longer where the law requires. Records are stored securely and can be made available promptly to competent authorities.

12Training

Everyone at Sherview receives financial-crime training when they join and at least once a year, tailored to their role and to the risks of our clients and services.

13Data protection

Personal data collected for due diligence is used only for that purpose and for meeting our legal obligations. It is processed in accordance with Law 81 of 2019 and the data-protection laws of each jurisdiction where we operate.