AML & KYC Policy

Arkan Capital Advisors maintains a comprehensive Anti-Money Laundering and Counter-Terrorism-Financing ("AML/CFT") framework, designed and operated in accordance with:

• The Saudi Anti-Money Laundering Law (Royal Decree No. M/20) and its Implementing Regulations.
• The Law on Combating the Financing of Terrorism (Royal Decree No. M/21) and its Implementing Regulations.
• The CMA's Anti-Money Laundering and Counter-Terrorism Financing Rules issued pursuant to the Capital Market Law.
• The SAMA Rules Governing Anti-Money Laundering and Combating the Financing of Terrorism, where applicable.
• The recommendations of the Financial Action Task Force (FATF) and the Middle East and North Africa Financial Action Task Force (MENAFATF).
• Applicable UN Security Council sanctions and the lists maintained by the Saudi Permanent Committee for Counter-Terrorism (Permanent Committee).

We apply a documented risk-based approach to assess and mitigate money-laundering and terrorism-financing risk across clients, products, services, distribution channels and geographies. An institution-wide risk assessment is performed at least annually and whenever a material change occurs. Clients are classified into low, standard, high or prohibited categories, and our controls scale accordingly.

Every prospective client — whether a natural person, legal entity, trust or similar arrangement — is subject to identification and verification before any business relationship is established or any transaction is executed. Standard CDD includes:

• Verification of identity using reliable, independent source documents (national ID, Iqama, passport, commercial registration, articles of association).
• Identification of ultimate beneficial owners (UBOs) holding 25% or more, or who otherwise exercise effective control.
• Understanding of the nature of business, ownership and control structure for legal persons.
• Identification of the purpose and intended nature of the relationship.
• Independent verification of source of wealth and source of funds.

Enhanced due diligence ("EDD") and senior-management approval are required before onboarding or continuing relationships that present higher risk, including: politically exposed persons (PEPs) and their immediate family members and close associates; clients connected to higher-risk jurisdictions; complex ownership structures; cash-intensive businesses; and any relationship flagged through screening or transaction monitoring. EDD measures include additional documentary evidence, deeper source-of-funds enquiries, and enhanced ongoing monitoring.

All clients, related parties and UBOs are screened at onboarding and on a continuous basis against United Nations, Permanent Committee, OFAC, EU, UK and other applicable sanctions lists, as well as recognised PEP and adverse-media databases. Any positive or potential match is investigated by the Compliance team and escalated to the MLRO for disposition.

Client relationships and transactions are monitored on a continuous basis through a combination of automated rules, behavioural analytics and analyst review. Triggers include unusual transaction size, frequency, geography, instrument, deviation from established patterns, and changes in client circumstances. Periodic refreshes of CDD data are performed based on the client's risk rating.

Where suspicion of money laundering, terrorism financing, or related predicate offences arises, the MLRO files a Suspicious Transaction Report (STR) with the Saudi Financial Intelligence Unit ("SAFIU") promptly and without notice to the client. We will not knowingly conduct a transaction we suspect to be linked to criminal activity.

All CDD documentation, transaction records, internal investigations and STRs are retained securely for not less than ten (10) years from the end of the business relationship or the date of the transaction, whichever is later, in line with the Saudi AML Law and CMA AML Rules. Records are made available to competent authorities upon lawful request.

Disclosing to a client or to any third party that an STR has been filed, or that an investigation is being or may be undertaken, is strictly prohibited and is a criminal offence under Saudi law. All staff are bound by enhanced confidentiality obligations with respect to AML/CFT matters.

The Board has appointed a Money Laundering Reporting Officer (MLRO) of sufficient seniority and independence, who reports directly to the Board's Risk & Compliance Committee. All staff complete onboarding and annual AML/CFT training, with role-based modules for front office, operations, technology and senior management. Training completion is monitored and recorded.

The effectiveness of the AML/CFT framework is reviewed at least annually by an independent function (internal audit or an external specialist), and findings are reported to the Audit Committee with tracked remediation plans.

Arkan cooperates fully with the CMA, SAMA, SAFIU, the Permanent Committee, the Public Prosecution and other competent authorities in matters relating to AML/CFT, sanctions and financial-crime investigations. Lawful information requests are handled by the Compliance function under MLRO oversight. Enquiries may be addressed to compliance@arkanlimited.com.