AML & Compliance Policy

Illunwo Bank maintains an unwavering commitment to the highest standards of Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and financial crime prevention. We recognize that the integrity of the global financial system depends on every financial institution playing its part in detecting, preventing, and reporting financial crime. Our compliance program is built on four foundational pillars: Prevention: Robust controls designed to prevent our platform from being used for money laundering, terrorist financing, sanctions evasion, or other financial crimes. Detection: Sophisticated transaction monitoring systems and behavioral analytics that identify suspicious patterns and anomalies in real time. Reporting: Timely and accurate reporting of suspicious activity to relevant financial intelligence units and regulatory authorities as required by law. Cooperation: Full cooperation with law enforcement, regulatory authorities, and financial intelligence units in investigations of financial crime. Our compliance framework is reviewed and updated regularly to reflect changes in applicable laws, regulations, and industry best practices. All staff receive mandatory AML/CFT training upon joining and annually thereafter.

Illunwo Bank conducts thorough Know Your Customer (KYC) due diligence on all clients before establishing a banking relationship and on an ongoing basis throughout the relationship. Our KYC program includes: Customer Identification Program (CIP): We verify the identity of all clients using government-issued identification documents. For individual clients, this includes passport, national ID, or driver's license. For corporate clients, this includes articles of incorporation, certificate of good standing, and beneficial ownership documentation. Customer Due Diligence (CDD): We collect and verify information about the nature and purpose of the banking relationship, expected transaction patterns, and source of funds. This information forms the basis of our risk assessment for each client. Enhanced Due Diligence (EDD): Clients identified as higher risk — including Politically Exposed Persons (PEPs), clients from high-risk jurisdictions, and clients with complex ownership structures — are subject to enhanced due diligence measures, including senior management approval, more frequent reviews, and enhanced transaction monitoring. Ongoing Monitoring: We continuously monitor client relationships and transactions to ensure they remain consistent with our understanding of the client's business and risk profile. We update KYC information when material changes occur or at scheduled review intervals. Beneficial Ownership: For corporate clients, we identify and verify all beneficial owners holding 25% or more of the entity, as well as any individuals exercising effective control.

Illunwo Bank maintains a comprehensive sanctions compliance program to ensure we do not conduct business with sanctioned individuals, entities, or jurisdictions. Sanctions Screening: All clients and transactions are screened against applicable sanctions lists, including: • OFAC (Office of Foreign Assets Control) — SDN and other lists • UN Security Council Consolidated Sanctions List • EU Consolidated Financial Sanctions List • UK HM Treasury Financial Sanctions List • Other applicable national and international sanctions lists Screening is conducted at onboarding, at regular intervals, and in real time for all transactions. Positive matches trigger an immediate freeze of the relevant transaction and escalation to our Compliance team. Politically Exposed Persons (PEPs): We identify and apply enhanced due diligence to PEPs — individuals who hold or have held prominent public positions — and their close associates and family members. PEP status does not automatically disqualify a client, but requires senior management approval and enhanced ongoing monitoring. Adverse Media Screening: We screen clients against adverse media sources to identify negative news that may indicate financial crime risk, reputational concerns, or regulatory issues. All screening is conducted using industry-leading screening technology with regular list updates to ensure accuracy and completeness.

Illunwo Bank employs a multi-layered transaction monitoring program to detect suspicious activity: Automated Monitoring: Our transaction monitoring system analyzes all transactions in real time using rule-based alerts and machine learning models. Alert scenarios include, but are not limited to: • Transactions inconsistent with the client's stated business or expected activity • Structuring — multiple transactions designed to avoid reporting thresholds • Rapid movement of funds through accounts (layering) • Transactions involving high-risk jurisdictions • Unusual cash-equivalent transactions • Transactions with no apparent economic purpose Risk-Based Approach: Transaction monitoring thresholds and alert parameters are calibrated based on client risk profiles. Higher-risk clients are subject to more sensitive monitoring parameters. Alert Investigation: All alerts generated by our monitoring system are reviewed by trained compliance analysts. Alerts are investigated, documented, and either cleared with supporting rationale or escalated for further review. Suspicious Activity Reporting: Where investigation confirms or reasonably suspects money laundering, terrorist financing, or other financial crime, we file Suspicious Activity Reports (SARs) with the relevant financial intelligence unit. We are prohibited by law from disclosing SAR filings to the subject of the report (tipping off).

Illunwo Bank complies with all applicable regulatory reporting requirements, including: Currency Transaction Reports (CTRs): We file CTRs for cash transactions exceeding applicable thresholds as required by law. Suspicious Activity Reports (SARs): We file SARs when we know, suspect, or have reason to suspect that a transaction involves funds derived from illegal activity, is designed to evade reporting requirements, or lacks a lawful purpose. Foreign Account Tax Compliance Act (FATCA): We comply with FATCA reporting requirements for US persons and entities. Common Reporting Standard (CRS): We participate in the OECD Common Reporting Standard for automatic exchange of financial account information between tax authorities. Record Keeping: We maintain all required records for the periods specified by applicable law, typically a minimum of 5-7 years. All regulatory reports are filed accurately, completely, and within required timeframes. We maintain a dedicated Compliance team responsible for regulatory reporting and liaison with regulatory authorities.

Illunwo Bank will not establish or maintain relationships with, or process transactions for: Prohibited Clients: • Individuals or entities on applicable sanctions lists • Shell banks (banks with no physical presence in any jurisdiction) • Clients who refuse to provide required KYC documentation • Clients whose source of funds cannot be satisfactorily explained • Clients operating in prohibited industries (see below) Prohibited Industries: • Unlicensed money service businesses • Illegal arms dealers or manufacturers • Narcotics trafficking operations • Human trafficking or exploitation • Terrorist organizations or their financiers • Unlicensed gambling operations • Businesses engaged in fraud or financial crime Prohibited Transactions: • Transactions with sanctioned jurisdictions or entities • Transactions with no apparent legitimate business purpose • Transactions designed to circumvent reporting requirements • Transactions involving proceeds of crime We reserve the right to refuse any transaction or terminate any relationship where we have concerns about compliance with applicable laws or our internal policies, without being required to provide a reason.

Our compliance program is governed by a robust framework of policies, procedures, and oversight: Chief Compliance Officer (CCO): Our CCO has overall responsibility for the design, implementation, and oversight of our compliance program. The CCO reports directly to senior management and the Board. Compliance Committee: A senior-level Compliance Committee meets regularly to review compliance program effectiveness, emerging risks, regulatory developments, and significant compliance matters. Independent Audit: Our compliance program is subject to regular independent audit by qualified external auditors. Audit findings are reported to senior management and the Board, and remediation is tracked to completion. Training: All staff receive mandatory AML/CFT training upon joining and annually thereafter. Staff in higher-risk roles receive additional specialized training. Training records are maintained for regulatory inspection. Whistleblower Protection: We maintain a confidential reporting channel for staff to report compliance concerns without fear of retaliation. Reports are investigated promptly and impartially. Regulatory Relationships: We maintain open and cooperative relationships with our regulatory supervisors and respond promptly and completely to all regulatory inquiries and examinations.

For compliance-related inquiries, to report suspicious activity, or for questions about our AML/CFT program, please contact: Compliance Department Illunwo Bank Email: compliance@illunwobank.com Confidential Reporting: whistleblower@illunwobank.com If you suspect that your account has been compromised or used for unauthorized transactions, please contact us immediately at security@illunwobank.com or call +1 (800) ILW-BANK. This AML/Compliance Policy was last updated on August 21, 2026.