Anti-Money Laundering & Know Your Counterparty (KYC) Policy and Procedure

1. Introduction

This policy confirms Nouvel Héritage’s commitment to preventing money laundering and the financing of terrorism in its business practices and transactions. Money laundering is the process of disguising the financial proceeds of crime to conceal their illegal origin. Terrorist financing refers to any kind of financial support to individuals or groups who attempt to encourage, plan, or engage in terrorism.

2. Policy Oversight

The implementation and oversight of this policy is the responsibility of the Operations & Compliance Lead at Nouvel Héritage. This policy is reviewed annually and updated as needed.

Nouvel Héritage ensures that the policy is overseen by a qualified individual with:
- Industry-specific expertise
- Familiarity with our key counterparties (clients and retailers)
- Solid knowledge of money laundering typologies relevant to our sector

3. KYC Procedures

Nouvel Héritage has established a Know Your Counterparty (KYC) program to:
- Identify every organization and retail partner we deal with
- Understand the legitimacy of each business relationship
- Detect and respond to unusual or suspicious activity

To support this policy, Nouvel Héritage may request additional documentation or verification from counterparties— including suppliers, customers, and retail partners — if risk triggers are identified or to ensure regulatory alignment. This may include:

·       Basic identification and business legitimacy information

·       Clarification of the nature and purpose of the business relationship

·       Periodic reassessment of counterparties based on risk level

4. Commitment to RJC COP 10.1 & 10.2

In accordance with RJC Code of Practices, Nouvel Héritage commits to:

a) Establishing Counterparty Identity
- Verify legal name, registration, tax status, and beneficial ownership (UBO) when triggered by risk or regulation
- Perform jurisdictional risk screening (FATF, OFAC, UN Sanctions lists, etc.)

b) Understanding the Nature of the Business
- Confirm the purpose of the relationship (e.g. resale, manufacturing, export)
- Monitor transaction patterns for alignment with expected behavior

c) Monitoring and Reporting
- Continuously monitor transactions for suspicious or unusual activity
- Escalate red flags for internal compliance review
- File Suspicious Activity Reports (SARs) with appropriate authorities when required by law

5. Red Flag Indicators

Nouvel Héritage has adopted red flag screening based on FATF Risk-Based Guidance, including:
- Lack of industry knowledge or documentation
- Use of complex structures or intermediaries without clear reason
- Refusal to identify beneficial owners
- Frequent account or banking changes
- Unusual shipping routes or jurisdictions
- Use of cash in a non-standard manner
- Links to politically exposed persons (PEPs)
- Transactions that don’t make commercial sense

6. Cash Transactions

In line with COP 10.2, we:
- Maintain logs of all cash or cash-like transactions ≥ €10,000 / $10,000
- Aggregate linked transactions for evaluation
- Report transactions above thresholds when required by law

7. Retail Partner Screening

We apply all KYC and AML procedures to our retail and wholesale partners:
- Require business registration, resale certificate, and UBO identification
- Verify the legitimacy of their operations (website, store, trade shows)
- Monitor wholesale order flow against expected business behavior
- Cease business or escalate if red flags are identified

For high-risk counterparties, we may:
- Suspend transactions
- Conduct an on-site visit
- Perform beneficial ownership screening
- Reassess jurisdictional exposure

8. Internal Procedures & Tools

Nouvel Héritage further commits to:
- Keeping KYC records for a minimum of 5 years
- Assigning additional monitoring controls for higher-risk relationships
- Maintaining documentation of all onboarding, screening, and monitoring processes
- Providing mandatory training to relevant employees at least once per year
- Using third-party tools (e.g. government databases, sanctions lists, CRM flags) to support KYC implementation

9. Review & Endorsement

This policy is reviewed annually and updated based on:
- Changes in applicable law
- RJC guidance updates
- Business risk evolution

Signed/endorsed by: Operations & Compliance Lead

Camille McKenna, Founder & CEO

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Date of latest review: August 1, 2025