This Anti-Money Laundering Policy (“AML Policy”) outlines the principles and procedures adopted by IS6 Technologies Ltd (Mauritius) (“the Company”) to prevent its services from being used for money laundering or terrorism financing.

The Company is incorporated under the laws of the Republic of Mauritius and is regulated by the Financial Services Commission (FSC) under the Financial Services Act 2007.

All AML/CFT activities are carried out in accordance with the following legislation and guidelines:

• Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA)
• Financial Intelligence and Anti-Money Laundering Regulations 2018
• FSC AML/CFT Handbook
• United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Sanctions Act 2019
• FATF Recommendations and other international standards.

The Company is committed to:

• Preventing its services from being used for money laundering or terrorism financing;
• Establishing robust risk-based internal controls to detect and report suspicious activities;
• Complying with all FSC and FIU obligations; and
• Promoting high ethical and professional standards in financial operations.

Money laundering is the process by which criminals attempt to conceal the illicit origin of funds by converting, transferring, or integrating them into the legitimate financial system.

It includes:

• Conversion or transfer of property derived from criminal activity;
• Concealment or disguise of the true nature of proceeds; and
• Acquisition or use of property knowing it originates from unlawful acts.

• AML laws seek to deter criminals by making it harder to hide illegally obtained funds.
• Criminals use money laundering to disguise the source of proceeds from crime.
• Financial institutions must implement KYC/CDD controls and report suspicious transactions to the Financial Intelligence Unit (FIU) of Mauritius.

Examples of transactions that may indicate money laundering include:

• Unusually large or frequent cash transactions;
• Structuring deposits to avoid reporting thresholds;
• Spikes in activity inconsistent with the customer’s profile;
• Transactions linked to high-risk jurisdictions identified by the FATF or FIU;
• Transfers involving politically exposed persons (PEPs) or related parties;
• Transactions connected with gambling or cash-intensive businesses.

The Company implements automated and manual transaction monitoring procedures to identify suspicious patterns.

Monitoring includes screening against international sanctions lists (UN, EU, OFAC), PEP databases, and adverse media.

All alerts are reviewed by the Money Laundering Reporting Officer (MLRO), who determines whether a Suspicious Transaction Report (STR) should be filed with the FIU.

The objective of KYC/CDD is to verify the identity and understand the financial background of each customer to prevent misuse of the Company’s services.

The Company requires all clients to submit valid identification (e.g., passport or national ID), proof of residence, and proof of funding source prior to account activation.

Enhanced due diligence (EDD) is performed for high-risk clients, including PEPs and non-face-to-face customers.

KYC/CDD steps include:

• Collection of customer information;
• Verification of identity and address;
• Screening against sanctions and PEP lists;
• Periodic review and updating of customer data.

The Company maintains records for a minimum of 7 years after the end of the business relationship in accordance with FIAMLA requirements.

• All employees must report suspicious activity immediately to the MLRO.
• The MLRO evaluates each report and, if appropriate, submits an STR to the FIU.
• It is strictly prohibited to notify a customer that an STR has been filed (“tipping off”).
• All records related to transactions, identity verification, and internal communications shall be securely kept for a minimum of 7 years.

The Company reserves the right to refuse to process any transaction at any stage if it is suspected to be related to criminal activity or money laundering.

Such cases will be immediately reported to the FIU in accordance with FIAMLA and FSC guidelines.

Accounts involved in confirmed illegal activity may be frozen or terminated and subject to criminal investigation.

All employees receive annual AML/CFT training to recognize suspicious transactions and understand their reporting obligations.

Training records are maintained by the Compliance Department for audit purposes.

The Company’s AML/CFT framework is independently reviewed at least once per year to assess its effectiveness and ensure ongoing compliance with FSC and FIU requirements.

For any questions regarding this AML Policy or the Company’s AML/CFT procedures, please contact:
support@is6.com or the Company’s Money Laundering Reporting Officer (MLRO) at its registered office in Port-Louis, Mauritius.