FINANCIAL CRIME POLICY
JFK IMPORT-EXPORT LLC — CONFIRMA

*** Draft for review. These documents were prepared as a starting point and have not been reviewed by a lawyer. Do not execute or publish any of them without review by qualified counsel in each relevant jurisdiction — the United States for the entity, the Democratic Republic of the Congo for the counterparties, and any jurisdiction whose law a counterparty insists upon. ***


## Framework

This policy is applied to every counterparty, wherever situated. Where a counterparty is established in the Democratic Republic of the Congo, we also have regard to Law No. 04/016 of 19 July 2004 on the fight against money laundering and the financing of terrorism, and to the role of the Cellule de Renseignement Financier as the Congolese financial intelligence unit.

## Commitment

JFK IMPORT-EXPORT LLC does not facilitate money laundering, terrorist financing, sanctions evasion, bribery or tax evasion. This applies whether or not a particular obligation is legally imposed on us in a given jurisdiction. Where our commercial interest and this policy conflict, this policy governs.

## Before any relationship begins

We identify the applicant company and verify it against registration records. We identify beneficial owners and directors, verify their identity documents, and match a live image of the person against the document. We screen the company, its owners and its directors against applicable sanctions, politically exposed person and adverse media lists. We verify that the bank account is held in the company's own registered name, independently of whoever supplied the details. We establish the commercial rationale for the relationship.

Where a check cannot be performed automatically, it is performed by a person and recorded with a reference to the evidence. **A check that has not been performed is never recorded as passed**, and the person who runs a check cannot be the person who records its outcome.

Nothing is funded until this is complete and verified by a person other than the one who collected it.

## What we refuse outright

Any counterparty, owner or director appearing on an applicable sanctions list. Any structure whose beneficial ownership cannot be established. Payment to any account other than one in the counterparty's own registered name. Payment in cash, to an individual, or to a third party. Any transaction with no discernible commercial purpose. Any counterparty that will not answer a source of funds question.

## During the relationship

Screening is repeated on any change of ownership, control or bank details. A change of bank details suspends funding until verified by a call back to a number captured at onboarding, made by a person other than the one who requested the change.

Every funded receivable is reconciled monthly against the operator's own records and against cash actually received. Variances are investigated within five days.

## Bribery

We do not offer or accept anything of value to influence a decision. Counterparties confirm in writing that no inducement has been offered in connection with the approval of an invoice. A connection between a supplier's ownership and an individual who approves that supplier's invoices is disqualifying, and it is checked before onboarding completes.

## Reporting

Where we identify conduct that appears fraudulent or corrupt, we report it to the affected counterparty's internal audit function, and to law enforcement and regulators where required or appropriate. We may be prohibited by law from telling a counterparty that a report has been made, and in that case we will not do so.

## Records

Due diligence records, transaction records and screening results are retained for not less than seven years from the end of the relationship or the last transaction, whichever is later.

## Responsibility

A named officer of JFK IMPORT-EXPORT LLC is accountable for this policy. Concerns may be raised at legal@[DOMAIN] with a subject line beginning INTEGRITY, including anonymously. No counterparty or employee is disadvantaged for raising a concern in good faith.

Effective 19 August 2026.