Legal AML Control Identification Form

LEGAL AML CONTROL IDENTIFICATION FORM

This Legal AML Control Identification Form (the "Form") is entered into as of by and between Company Name: and AML Control Owner Name: (collectively, the "Parties").

RECITALS

WHEREAS, the Company operates in business lines subject to anti‑money laundering and counter‑terrorist financing obligations and maintains internal controls designed to mitigate money laundering risk; and

WHEREAS, the Parties desire to identify, document, assign ownership of, and certify the status of specific AML controls, including responsibilities for implementation, monitoring, testing, remediation, and recordkeeping; and

WHEREAS, this Form establishes a written record that will be used for compliance oversight, internal audit review, and regulatory examination readiness.

NOW, THEREFORE, in consideration of the mutual covenants contained herein, the Parties agree as set forth below.

1. DEFINITIONS

For purposes of this Form, "AML Control" means a specific policy, procedure, system or process implemented to prevent, detect, report or remediate activity that could facilitate money laundering or terrorist financing. "Control Owner" means the individual identified as having primary responsibility for the operation and oversight of the AML Control.

2. CONTROL IDENTIFICATION

The Company hereby documents the following AML Controls. For each control, provide a unique identifier, concise description, control category, frequency of operation, current operational status, most recent test date, and location of supporting documentation.

Control 1

Transaction monitoring Know Your Customer / Customer Due Diligence Sanctions screening

Operational Pending Remediation Decommissioned

Control 2

3. RISK ASSESSMENT AND RATIONALE

Each control identified above must be mapped to one or more risk categories and justified by the Control Owner. Provide the primary risk categories addressed and a concise rationale for the selected control design.

Customer risk Product / service risk Geographic / jurisdictional risk Transactional risk

4. MONITORING, TESTING AND REPORTING

Control Owners must implement monitoring and testing procedures sufficient to evaluate ongoing effectiveness. Where testing identifies deficiencies, the Control Owner must document remediation plans and escalate as required by Company policy.

5. REMEDIATION PLAN

If a control is assessed as partially effective or ineffective, provide a remediation plan with target completion dates and responsible party.

6. RECORDKEEPING AND RETENTION

All documentation supporting control operation, monitoring and testing must be retained in accordance with the Company's record retention policy and applicable legal requirements.

7. TRAINING AND COMPETENCY

Control Owners must ensure appropriate personnel receive role‑based AML training and that training completion is documented and retained.

8. AUDIT AND INDEPENDENT TESTING

Controls will be subject to independent testing by internal audit or an external assessor. Test results, exceptions, and corrective actions will be documented and assigned for remediation.

9. CERTIFICATION

The undersigned Control Owner certifies, to the best of their knowledge and belief, that the information provided in this Form is true, complete, and accurately reflects the design and operating status of the identified AML controls. The Control Owner further certifies that they will implement or supervise remediation for any deficiencies and will notify the Compliance function of material issues in accordance with Company policy.

I certify the accuracy of the information contained in this Form and acknowledge that knowingly providing false information may result in disciplinary action, up to and including termination, and may subject me to civil or criminal liability.

10. NOTICES

All notices required or permitted under this Form shall be in writing and delivered to the addresses set forth below by hand, courier, or certified mail, or by documented electronic transmission to an address designated for notices.

11. AMENDMENTS, WAIVER, COUNTERPARTS

This Form may be amended only by a written instrument signed by both Parties. No waiver of any provision of this Form shall be effective unless in writing and signed by the Party against whom the waiver is asserted. This Form may be executed in counterparts, each of which shall be deemed an original and all of which together shall constitute one and the same instrument.

12. GOVERNING LAW; SEVERABILITY; ENTIRE AGREEMENT

This Form shall be governed by and construed in accordance with the laws of the jurisdiction in which the Company is incorporated, without regard to its conflict of law principles. If any provision of this Form is held to be invalid or unenforceable, the remaining provisions shall continue in full force and effect. This Form constitutes the entire agreement between the Parties with respect to the subject matter hereof and supersedes all prior and contemporaneous agreements, representations, and understandings, whether written or oral.

13. SEVERABILITY

If any provision of this Form is determined by a court of competent jurisdiction to be invalid, illegal or unenforceable, such determination shall not affect the validity or enforceability of any other provision, all of which shall remain in full force and effect.

CERTIFICATION BY CONTROL OWNER

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