Money laundering refers to the process where the identity of the proceeds generated from crime is disguised so as to portray the appearance of a legitimate income. Halebore Limited acknowledges that it is common for criminals to specifically target firms which are providing financial services through which they attempt to launder criminal proceeds without such firm’s knowledge or suspicions.

Halebore Limited has implemented systems and procedures that meet the AML legislation of the UK. This decision reflects the senior management desire to prevent money laundering and not be used by criminals to launder proceeds of crime.

Halebore Limited is fully compliant with the relevant anti-money laundering legislation of the UK:

• Anti-Money Laundering and Suppression of Terrorist Financing Code of Practice, 2014, SRO 10 of 2014;

• Money Laundering (Prevention) (Amendment) Act 2001, ACT 13 of 2001;

• Money Laundering (Prevention) (Amendment) (No. 2) Act 2013, Act 8 of 2013;

• Money Laundering (Prevention) (Amendment) Act, 2004, Act 4 of 2004;

• Money Laundering (Prevention) (Amendment) Act, 2016, ACT 2 of 2016;

• Money Laundering (Prevention) (Amendment) Regulation 2013, SRO 14 of 2013;

• Money Laundering (Prevention) (Amendment) Regulations 2013, Act 14 of 2013;

• Money Laundering (Prevention) (Amendment) Regulations, 2014, SRO 33 of 2014;

• Money Laundering (Prevention) Act, 2000, Act 20 of 2000;

• Money Laundering (Prevention) Act, 2011, Act No. 8 of 2011;

• Money Laundering (Prevention) Regulations, 2013, SRO 4 of 2013;

• Money Laundering (Prevention)(Amendment) Act, 2013., Act 5 of 2013;

We reserve the right to refuse to accept you as a client, terminate our relationship with you with immediate effect, to refuse to execute any pending orders and to freeze or block your account with us and any assets thereon if:

(i) we reasonably believe that you may be acting in breach of the anti-money laundering legislation of the UK or any other jurisdiction; or

(ii) if you refuse to provide us either at the account opening stage or at any subsequent stage that we determine at our discretion any information about you that we require you to provide, including your updated proof of identity and residence.

Sanctions Policy

Our sanctions policy is designated to ensure our compliance with the laws and regulations in the applicable jurisdictions in which we operate. Halebore Limited is prohibited from executing transactions with individuals, companies or countries which are on the prescribed Sanctions lists. Halebore Limited will, therefore, screen against United Nations, European Union and US Office of Foreign Assets Control (the “OFAC”) sanctions lists in all jurisdictions in which we operate, except if such screening conflicts with local legislation.