Exura Prime

AML/CTF & KYC Policy

Exura Prime's anti-money-laundering, counter-terrorist-financing and know-your-client framework: the checks applied at onboarding and on an ongoing basis, the documents required, sanctions screening, restricted jurisdictions and reporting obligations.

Effective date: August 2026

This page summarises the anti-money-laundering, counter-terrorist-financing and know-your-client framework of Exura Prime Ltd ("Exura Prime", the "Company") — authorised and regulated by the Financial Services Commission of Mauritius (the "FSC") as an Investment Dealer (Full Service Dealer, excluding Underwriting), Licence No. GB26206361, registration number 235905 GBC. It forms part of the Agreement described in the Terms of Business.

1. Legal framework

The Company maintains AML/CTF controls in accordance with the laws of Mauritius, including the Financial Intelligence and Anti-Money Laundering Act 2002 and the Financial Intelligence and Anti-Money Laundering Regulations 2018, the Prevention of Terrorism Act 2002, related sanctions legislation, and applicable FSC rules, codes and guidance — together with international standards issued by the Financial Action Task Force (FATF) — as amended from time to time (the "AML/CTF Regime").

2. Risk-based programme

The Company applies a risk-based programme comprising:

  • Customer due diligence (KYC/KYB) — identification and verification of every client before establishing a business relationship, with enhanced due diligence for higher-risk clients and relationships;
  • Beneficial-ownership verification — identification of shareholders, beneficial owners, directors and authorised representatives, with verification of beneficial owners holding, directly or indirectly, 25% or more (or such lower threshold as the Company applies on a risk basis);
  • Sanctions screening — screening of clients and related persons against the sanctions lists of the United Nations and Mauritius, and against relevant lists administered by OFAC (US), the European Union and the United Kingdom, at onboarding and on an ongoing basis;
  • PEP screening — identification of politically exposed persons, their family members and close associates, with enhanced due diligence and senior-management approval where a PEP relationship is established;
  • Adverse media and reputational screening;
  • Source of funds and source of wealth verification — as required on a risk basis, and in any event in connection with funding of the account (see the Deposits & Withdrawals Policy);
  • Ongoing monitoring — transaction monitoring, periodic reviews of client files, and re-verification on trigger events (material changes, unusual activity, expiry of documents);
  • Record keeping — retention of identification and transaction records for the periods required under the AML/CTF Regime (at least seven years);
  • Reporting — internal escalation and reporting of suspicious activity to the Mauritius Financial Intelligence Unit and cooperation with competent authorities, as required by law;
  • Training and governance — a designated compliance function, periodic staff training, and independent review of the programme.

3. Who we onboard — and who we do not

3.1. Services are provided exclusively to professional and eligible counterparties: institutions, and individuals who qualify on net worth and investment experience. Registration is open to companies and individuals; account approval is subject to the checks described here, and the Company may request additional information or documents at any stage of the relationship.

3.2. The Company may decline any application, and may restrict, suspend or terminate any relationship, where its legal, regulatory, compliance or risk-management requirements are not satisfied — without being obliged to give reasons, and with reporting to competent authorities where required.

3.3. The Company does not establish or maintain relationships with sanctioned or designated persons or entities, with persons owned or controlled by them, or with persons or entities resident or incorporated in the Company's restricted jurisdictions, as listed on the Legal Information page — nor in any jurisdiction included on applicable sanctions lists. The restricted list is maintained by compliance and reviewed periodically.

4. Documents required

Individuals (including directors, authorised representatives and beneficial owners of corporate clients):

  • Valid passport or government-issued photo identification;
  • Proof of residential address not older than three months (utility bill or bank statement);
  • Tax residency information (FATCA/CRS self-certification);
  • For qualifying individual clients: evidence supporting eligibility (net worth and investment experience), and source-of-funds/wealth documentation as requested.

Corporate clients:

  • Certificate of incorporation and constitutional documents (memorandum and articles or equivalent);
  • Registers of shareholders and directors;
  • Identification and proof of address for directors, authorised representatives and beneficial owners (25% or more);
  • Proof of registered address (and operating address, if different) not older than three months;
  • Latest financial statements or recent bank statements;
  • Regulatory licences where the client's activities require them;
  • FATCA/CRS entity self-certification.

Additional documentation may be required depending on the structure, jurisdiction and risk profile of the applicant. The Company may use reputable third-party electronic verification providers to assist with identity verification; by applying, you consent to the disclosure of your information for that purpose.

5. Ongoing obligations of clients

Clients must keep their information current and notify the Company of material changes (in any event within five business days), respond to requests for updated documentation, and refrain from any use of the account for unlawful purposes. Funds transferred to the Company must originate from lawful sources; the Company applies the same-name and return-to-source rules described in the Deposits & Withdrawals Policy.

6. Consequences of non-compliance

Where checks cannot be completed, information is refused, or activity gives rise to concern, the Company may: decline or delay transactions and withdrawals; restrict, suspend or terminate the account; retain funds where required by law or a competent authority; and file reports with the relevant authorities. The Company may be prohibited by law from disclosing that a report has been made.

This page is a summary of the Company's framework, published for transparency; the Company's internal policies and procedures, and the AML/CTF Regime itself, prevail over this summary. The current version is always available on this page.

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