Anti-Money Laundering (AML) Policy

Last updated: 7 July 2025

HAKO Global Trading Limited ("the Company") is a Hong Kong registered entity engaged in international vehicle export. We are committed to preventing our services from being used for money laundering, terrorism financing, or other illicit purposes.

This Anti-Money Laundering (AML) Policy describes the framework we apply to identify, assess, and mitigate money laundering and terrorist financing risks, in accordance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) of Hong Kong ("AMLO").

1. Company Commitment

The Company maintains a strong commitment to AML compliance. Our senior management is responsible for ensuring that adequate resources, systems, and controls are in place to identify and mitigate money laundering risks. We do not conduct business with customers who refuse to provide required information or who are suspected of engaging in illicit activity.

2. Risk-Based Approach

2.1 Risk Assessment

The Company applies a risk-based approach to AML compliance. We assess the money laundering and terrorist financing risk of each customer and transaction based on factors including:

• The customer's country of residence or incorporation;
• The destination country of the vehicle;
• The nature of the customer (individual, corporate, or government);
• The payment method and source of funds;
• The transaction value and complexity;
• Any unusual or inconsistent patterns of behaviour.

2.2 Risk Categorisation

Customers are categorised as low, medium, or high risk. Higher-risk customers are subject to enhanced due diligence, including additional documentation, senior management approval, and more frequent transaction monitoring.

2.3 High-Risk Indicators

Transactions that present any of the following indicators are treated as high risk:

• Payments from third parties not named on the order;
• Payments in cash or cash-equivalent instruments;
• Requests to route payments through multiple jurisdictions without legitimate business reasons;
• Customers based in or connected to high-risk jurisdictions as identified by the Financial Action Task Force (FATF);
• Transactions that do not match the customer's known profile or business activity.

3. Customer Due Diligence (CDD)

The Company conducts Customer Due Diligence on all customers before entering into a business relationship or carrying out a transaction. The scope of CDD depends on the risk categorisation and is described in detail on our KYC Information page.

Where CDD cannot be satisfactorily completed, the Company will not establish or continue the business relationship and may file a suspicious transaction report.

4. Transaction Monitoring

4.1 Ongoing Monitoring

The Company monitors transactions on an ongoing basis to ensure they are consistent with the customer's known profile, business activity, and risk categorisation. Monitoring includes:

• Verifying that payment origin matches the customer's identified bank account;
• Checking for unusual payment structures or jurisdictions;
• Reviewing vehicle destination and shipping routes against sanctions lists;
• Identifying transactions that deviate from expected patterns.

4.2 Enhanced Monitoring

High-risk customers and transactions are subject to enhanced monitoring, including:

• Additional verification of the source of funds;
• Senior management review and approval;
• More frequent re-screening against sanctions lists;
• Retention of additional supporting documentation.

5. Suspicious Activity Reporting

Where the Company knows or suspects that a customer, transaction, or property is connected to money laundering, terrorist financing, or other criminal activity, we will:

1. Seek the consent of the Joint Financial Intelligence Unit (JFIU) of Hong Kong before completing the transaction, where required by the AMLO;
2. File a Suspicious Transaction Report with the JFIU;
3. Not disclose to the customer or any third party that a report has been made (tipping off is a criminal offence under Hong Kong law);
4. Retain all relevant records and documentation.

6. Sanctions Screening

The Company screens all customers, beneficial owners, and transaction counterparts against published sanctions lists at onboarding and on an ongoing basis. The lists screened include those maintained by the United Nations, the European Union, the United Kingdom, the United States, and Hong Kong authorities.

Where a match is identified, the transaction is suspended pending investigation. Confirmed matches result in transaction refusal, account termination, and reporting to the relevant authorities.

7. Record Keeping

The Company maintains records of all transactions, customer identification documents, and AML screening results for a minimum of six (6) years from the date of the transaction or the end of the business relationship, whichever is later.

Records are stored securely and are accessible to authorised personnel and competent authorities upon lawful request.

8. Compliance Responsibilities

8.1 Management Oversight

The Company's senior management is ultimately responsible for AML compliance. A designated compliance officer is responsible for the day-to-day implementation of this policy.

8.2 Employee Training

All employees receive AML training appropriate to their role, including identification of suspicious activity, sanctions screening procedures, and reporting obligations. Training is refreshed at least annually.

8.3 Independent Review

The Company's AML framework is subject to periodic independent review to ensure its effectiveness and compliance with applicable laws.

9. Customer Cooperation

Customers are required to cooperate with the Company's AML procedures, including:

• Providing accurate and complete KYC documentation;
• Disclosing the source of funds where requested;
• Consenting to sanctions screening and transaction monitoring;
• Notifying the Company of any change in beneficial ownership or business structure.

Refusal to cooperate may result in the refusal or termination of services.

10. Contact

For questions regarding this AML Policy, please contact us:

• Company: HAKO Global Trading Limited
• Email: CONTACT@hakoautomobile.com
• WhatsApp: +213 780 442 267