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Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

Last Updated: October 19, 2025

1. Introduction and Purpose

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy establishes the framework for Trowe Price Tech's compliance with applicable laws and regulations designed to prevent:

• Money laundering and terrorist financing
• Fraud and identity theft
• Market manipulation and insider trading
• Tax evasion and sanctions violations
• Other financial crimes and illegal activities

We comply with all applicable regulations, including but not limited to:

• Bank Secrecy Act (BSA)
• USA PATRIOT Act
• Financial Crimes Enforcement Network (FinCEN) regulations
• Office of Foreign Assets Control (OFAC) requirements
• Financial Action Task Force (FATF) recommendations
• Securities and Exchange Commission (SEC) rules
• Financial Industry Regulatory Authority (FINRA) regulations

2. Know Your Customer (KYC) Requirements

2.1 Customer Identification Program (CIP)

All users must complete our Customer Identification Program before accessing our services. We collect and verify the following information:

• Full legal name (as it appears on government-issued identification)
• Date of birth
• Residential address (P.O. boxes are not accepted)
• Nationality and country of residence
• Government-issued identification number (passport, driver's license, or national ID)
• Social Security Number or Tax Identification Number
• Contact information (email address and phone number)

2.2 Identity Verification

We verify customer identities through multiple methods:

• Document verification using government-issued photo identification
• Biometric verification (facial recognition and liveness detection)
• Address verification through utility bills or bank statements
• Database checks against public and private records
• Third-party identity verification services
• Credit bureau checks where applicable

2.3 Enhanced Due Diligence (EDD)

We apply Enhanced Due Diligence for high-risk customers, including:

• Politically Exposed Persons (PEPs)
• Customers from high-risk jurisdictions
• Customers with complex ownership structures
• High-net-worth individuals with significant transaction volumes
• Customers engaged in high-risk industries

Enhanced Due Diligence procedures include:

• Additional documentation and information requirements
• Source of funds and source of wealth verification
• Adverse media screening
• Beneficial ownership identification
• Ongoing monitoring and periodic reviews

2.4 Business Accounts and Corporate Verification

Business and institutional accounts require additional verification:

• Certificate of incorporation or business registration documents
• Articles of association or bylaws
• Proof of business address
• Tax registration certificates
• Board resolutions authorizing account opening
• Identification of beneficial owners (25% or greater ownership)
• Identification of authorized signatories and trading personnel
• Business license or regulatory approval documents

3. Customer Risk Assessment

We conduct risk-based assessments of all customers using the following criteria:

3.1 Risk Factors

• Geographic risk (customer location and transaction destinations)
• Customer type (individual, business, trust, etc.)
• Product and service usage patterns
• Transaction volume and frequency
• Occupation and industry sector
• Source of funds and wealth
• Expected account activity
• Delivery channels utilized

3.2 Risk Categories

Customers are classified into risk categories:

• Low Risk: Standard verification and monitoring
• Medium Risk: Enhanced verification and regular monitoring
• High Risk: Enhanced Due Diligence and continuous monitoring
• Prohibited: Account opening declined or existing account closed

4. Transaction Monitoring and Reporting

4.1 Ongoing Monitoring

We continuously monitor customer accounts and transactions for suspicious activity using:

• Automated transaction monitoring systems
• Real-time alerts for unusual activity
• Pattern recognition and behavioral analysis
• Threshold-based alerts
• Artificial intelligence and machine learning algorithms
• Manual review by compliance specialists

4.2 Suspicious Activity Indicators

We investigate transactions that exhibit red flags, including:

• Transactions inconsistent with customer profile or normal activity
• Unusual transaction patterns or sudden changes in activity
• Transactions with no apparent business or lawful purpose
• Attempts to evade reporting thresholds (structuring)
• Transactions involving high-risk jurisdictions
• Rapid movement of funds
• Transactions involving shell companies or intermediaries
• Reluctance to provide information or documentation
• Use of multiple accounts or identities

4.3 Suspicious Activity Reports (SARs)

When suspicious activity is identified, we file Suspicious Activity Reports with FinCEN and other relevant authorities as required by law. We maintain strict confidentiality regarding SAR filings and do not notify customers that a report has been filed.

4.4 Currency Transaction Reports (CTRs)

We file Currency Transaction Reports for transactions exceeding regulatory thresholds as required by applicable law.

5. Sanctions Screening and Compliance

5.1 Screening Requirements

We screen all customers, transactions, and counterparties against:

• OFAC Specially Designated Nationals (SDN) List
• United Nations Security Council Sanctions Lists
• European Union Sanctions Lists
• HM Treasury Financial Sanctions Lists
• Other applicable government sanctions lists
• Politically Exposed Persons (PEP) databases
• Adverse media and law enforcement databases

5.2 Screening Frequency

• At account opening and customer onboarding
• Real-time screening of all transactions
• Daily batch screening of existing customers
• Upon sanction list updates
• Periodic reviews based on customer risk rating

5.3 Match Resolution

When a potential sanctions match is identified, we:

• Immediately freeze the account or transaction
• Conduct detailed investigation to confirm or dismiss the match
• Document the investigation and decision-making process
• Report confirmed matches to appropriate authorities
• Reject or terminate relationships with sanctioned parties

6. Recordkeeping Requirements

We maintain comprehensive records in compliance with regulatory requirements:

6.1 Records Retained

• Customer identification and verification documents
• Account opening documentation
• Transaction records and confirmations
• Communication records with customers
• Risk assessments and due diligence reports
• Sanctions screening results
• Suspicious activity investigations and reports
• Training records for staff
• Audit trails and system logs

6.2 Retention Periods

Records are retained for a minimum of:

• Customer identification records: 5 years after account closure
• Transaction records: 5 years after the transaction date
• Suspicious activity records: 5 years after SAR filing
• Other compliance records: As required by applicable law

7. Prohibited Activities and Account Restrictions

7.1 Prohibited Customers

We do not accept customers who:

• Appear on sanctions lists or are from sanctioned jurisdictions
• Fail to provide required identification or documentation
• Provide false or misleading information
• Are involved in illegal activities
• Refuse to cooperate with compliance procedures
• Have been convicted of financial crimes

7.2 Prohibited Transactions

We prohibit transactions involving:

• Illegal goods or services
• Sanctioned individuals, entities, or jurisdictions
• Money laundering or terrorist financing
• Market manipulation or insider trading
• Tax evasion schemes
• Ponzi schemes or fraudulent investment opportunities
• Unlicensed money transmission

7.3 Account Closure and Termination

We reserve the right to close accounts and terminate relationships when:

• Customers fail to provide updated KYC information
• Suspicious activity cannot be adequately explained
• Customers are identified on sanctions lists
• Customers engage in prohibited activities
• Risk levels exceed our risk appetite
• Required by law or regulatory authorities

8. Staff Training and Awareness

We maintain a comprehensive AML/KYC training program:

• Mandatory training for all employees upon hire
• Annual refresher training for all staff
• Specialized training for compliance personnel
• Updates on regulatory changes and emerging risks
• Testing and certification requirements
• Documentation of all training activities

9. Compliance Governance and Oversight

9.1 Compliance Officer

We have designated a Chief Compliance Officer responsible for:

• Overseeing the AML/KYC program
• Ensuring regulatory compliance
• Reviewing suspicious activity and filing reports
• Liaising with regulatory authorities
• Managing compliance staff and resources
• Reporting to senior management and board of directors

9.2 Independent Testing and Audits

Our AML/KYC program is subject to:

• Annual independent audits by qualified third parties
• Regular internal compliance reviews
• Regulatory examinations and assessments
• Technology system testing and validation

9.3 Program Updates and Improvements

We continuously review and update our AML/KYC program to:

• Incorporate regulatory changes
• Address audit findings and recommendations
• Respond to emerging risks and typologies
• Implement technological enhancements
• Improve efficiency and effectiveness

10. Customer Obligations and Cooperation

As a condition of using our services, customers must:

• Provide accurate, complete, and truthful information
• Submit required identification and documentation promptly
• Notify us of changes to personal information within 30 days
• Respond to requests for additional information or clarification
• Cooperate with compliance investigations
• Acknowledge that accounts may be frozen during investigations
• Accept that we may decline transactions or close accounts
• Understand that we cannot disclose certain compliance actions

11. Privacy and Confidentiality

While we collect extensive information for compliance purposes, we:

• Protect customer information with robust security measures
• Share information only as required by law or with customer consent
• Maintain confidentiality of compliance investigations
• Comply with data protection and privacy regulations
• Implement access controls and need-to-know principles

12. Reporting and Communication

Customers or employees who suspect money laundering, terrorist financing, or other financial crimes should immediately report concerns to:

• Email: compliance@t-rower-price.com
• Phone: +1 (212) 564-8800 (24/7 Compliance Hotline)
• Address: Compliance Department, 350 Fifth Avenue, Suite 7680, New York, NY 10118

We maintain a whistleblower protection policy and do not retaliate against individuals who report suspected violations in good faith.

13. International Compliance

For customers in multiple jurisdictions, we comply with:

• Local AML/KYC laws and regulations
• International standards and best practices
• Cross-border information sharing agreements
• Mutual legal assistance treaties

14. Policy Review and Updates

This policy is reviewed and updated at least annually or more frequently as needed to reflect:

• Changes in applicable laws and regulations
• Evolving money laundering and terrorist financing risks
• Technological developments
• Audit findings and recommendations
• Industry best practices

15. Contact Information

For questions about this AML/KYC Policy or compliance matters:

• Email: compliance@t-rower-price.com
• Phone: +1 (212) 564-8800
• Address: Chief Compliance Officer, 350 Fifth Avenue, Suite 7680, New York, NY 10118