Compliance

1. Regulatory Status

TranSecure Consulting Limited is registered in England and Wales and operates in accordance with applicable UK financial services legislation. Where we provide activities that constitute regulated payment services, we ensure these are conducted in compliance with the Payment Services Regulations 2017 and oversight from the Financial Conduct Authority (FCA).

Our commodities advisory activities are conducted in compliance with relevant commodity trading regulations. We take seriously our obligations under all applicable legislation and maintain an active compliance programme.

2. Anti-Money Laundering (AML)

We are fully committed to the prevention of money laundering, terrorist financing, and financial crime. Our AML programme is built in accordance with:

• The Proceeds of Crime Act 2002 (POCA)
• The Terrorism Act 2000
• The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended)
• FATF Recommendations and guidance
• HM Treasury and FCA guidance on financial crime

3. Know Your Customer (KYC)

We apply a risk-based approach to KYC in line with the Joint Money Laundering Steering Group (JMLSG) guidance. Depending on the nature and risk level of an engagement, we may require:

• Proof of identity (government-issued photo ID)
• Proof of address (utility bill or bank statement dated within 3 months)
• Ultimate Beneficial Owner (UBO) information for corporate clients
• Source of funds and source of wealth documentation for high-value engagements
• Company registration documents and certified constitutions where applicable

We use trusted third-party identity verification services to assist with electronic KYC checks where appropriate.

4. Sanctions Compliance

We do not conduct business with individuals or entities that are subject to financial sanctions imposed by the United Kingdom, United Nations, European Union, or United States Office of Foreign Assets Control (OFAC). We screen all clients and counterparties against current sanctions lists prior to engagement and on an ongoing basis.

Any potential sanctions match is escalated immediately to our compliance team for investigation before any services are provided or continued.

5. Data Protection in Compliance

Personal data collected for compliance purposes is processed in accordance with our Privacy Policy and applicable data protection legislation (UK GDPR and the Data Protection Act 2018). Compliance records are retained for a minimum of five (5) years as required by the Money Laundering Regulations.

6. Reporting Concerns

If you have concerns about potential financial crime, money laundering, or suspicious activity involving TranSecure Consulting or any of our clients, please report this through the appropriate channels:

• ▸Internal reports — Contact our Money Laundering Reporting Officer (MLRO) at mlro@transecurehub.com
• ▸External reports — Suspicious Activity Reports (SARs) may be filed directly with the National Crime Agency (NCA) at nationalcrimeagency.gov.uk
• ▸FCA concerns — Regulatory concerns may be reported to the Financial Conduct Authority (FCA) at fca.org.uk

7. Whistleblowing

We maintain a confidential whistleblowing channel for employees, contractors, and business partners to report concerns about illegal activity, regulatory breaches, or ethical violations without fear of retaliation. All reports are investigated promptly and confidentially by senior management.

8. Contact Our Compliance Team

For compliance-related enquiries or to submit documentation:

All compliance communications are treated with strict confidentiality.