In terms of the Prevention of Money Laundering and Funding of Terrorism Regulations (“PMLFTR”), the Company does not qualify as a “subject person” since it does not carry out any relevant financial business or relevant activity. It follows that the Company is therefore not subject to the responsibilities and obligations which emanate from AML/CFT legislation.
Without prejudice to the above, despite not being under a legal obligation to implement certain AML/CFT processes, the Company is still undertaking certain steps to mitigate the risk of ML/FT. Due diligence documentation and screening is still being undertaken on any of the investors participating in the private sale. The Company undertakes not to deal with any third parties that prima facie are deemed to present a high risk of ML/FT.