Anti-Money Laundering (AML) Policy

1. Legal Framework

This policy has been prepared in compliance with the following UAE legislation and regulatory frameworks:

• UAE Federal Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations, and its amendments
• Cabinet Decision No. 10 of 2019 on the Implementing Regulation of the above law
• UAE Federal Decree-Law No. 26 of 2021 amending certain provisions of Federal Law No. 20 of 2018
• The UAE Financial Intelligence Unit (FIU) guidelines and directives
• The Financial Action Task Force (FATF) recommendations, as applicable to the UAE

2. Know Your Customer (KYC) Requirements

Before entering into any investment arrangement, Globex Horizon applies Know Your Customer (KYC) procedures to verify the identity of prospective investors and, where applicable, the source of funds.

What We Require From All Investors

• Government-issued photo identification (passport or UAE Emirates ID)
• Proof of residential address dated within 3 months (utility bill, bank statement, or equivalent)
• Source of funds declaration — a description of the origin of the capital being invested
• For amounts above AED 500,000: supporting documentation evidencing source of wealth (salary slips, business ownership documentation, property sale records, or equivalent)
• For corporate investors: company registration documents, trade licence, ownership structure, and details of ultimate beneficial owners

Enhanced Due Diligence

Enhanced due diligence will be applied in the following circumstances:

• Where the investor is a Politically Exposed Person (PEP) or is closely associated with a PEP
• Where the investor is based in, or the funds originate from, a country identified as high-risk by the FATF or the UAE Central Bank
• Where the transaction is unusually large or the investment structure is complex without apparent legitimate purpose
• Where any element of the investor’s profile or the transaction raises a concern

3. Prohibited Investors and Transactions

Globex Horizon will not enter into any investment arrangement with, or accept funds from:

• Any person or entity listed on UAE, UN, EU, OFAC, or other applicable sanctions lists
• Any person or entity subject to UAE or international asset freezes
• Any person or entity reasonably suspected of involvement in money laundering, terrorist financing, or other financial crime
• Any person unable or unwilling to provide satisfactory KYC documentation
• Any anonymous investor — all investment arrangements require full identification

Globex Horizon reserves the right to decline any investment enquiry, suspend any ongoing arrangement, or terminate any relationship where AML or CTF concerns arise, without being required to provide reasons to the affected party.

4. Suspicious Transaction Reporting

In accordance with UAE Federal Law No. 20 of 2018, Globex Horizon is obligated to report any transaction or attempted transaction that raises reasonable grounds for suspicion of money laundering or terrorist financing to the UAE Financial Intelligence Unit (FIU) through the goAML platform.

Globex Horizon personnel are trained to recognise indicators of suspicious activity and are legally prohibited from tipping off any person who is the subject of a suspicious transaction report.

5. Record Keeping

In accordance with UAE AML law, Globex Horizon maintains records of all investor identification documents, investment transactions, and due diligence procedures for a minimum period of five years from the end of the investment relationship, or such longer period as may be required by law.

6. Training and Internal Controls

Globex Horizon ensures that relevant personnel are trained on AML and CTF obligations and are aware of their responsibilities under UAE law. Internal controls are reviewed periodically to ensure they remain effective and current with regulatory requirements.

7. Investor Obligations

By engaging with Globex Horizon, prospective and current investors confirm that:

• The funds being invested are derived from legitimate sources
• They are not subject to any sanctions, asset freezes, or legal restrictions on investment
• They will provide accurate, complete, and up-to-date KYC documentation as requested
• They will promptly notify Globex Horizon of any material change in their circumstances that may be relevant to AML compliance

Providing false or misleading information in connection with KYC or AML procedures is a serious offence under UAE law and may result in immediate termination of any investment relationship and referral to the relevant authorities.