Anti-Money Laundering Policy

Limitless Capital ("we", "us", "our") is committed to the highest standards of integrity in preventing our products and services from being used, directly or indirectly, to facilitate money laundering, terrorist financing, or breaches of financial sanctions.

This policy sets out the measures we adopt to identify our customers, monitor for suspicious activity, screen against sanctions lists, and respond appropriately where concerns arise. It applies to all directors, employees, and contractors of Limitless Capital.

Limitless Capital is not currently authorised or regulated by the Financial Conduct Authority, and, based on the nature of our current products and services (software licensing, bespoke development, and broker introductions), we do not consider ourselves to be a "relevant person" within the regulated sector for the purposes of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 ("the MLRs"). This assessment should be periodically reviewed with legal counsel as our services evolve.

This policy is adopted voluntarily, as a matter of good business practice and risk management, and is not a representation that Limitless Capital is subject to the formal statutory customer due diligence and reporting regime that applies to regulated-sector firms.

Certain legal obligations apply to all businesses and individuals in the UK regardless of regulated status, including the principal money laundering offences under the Proceeds of Crime Act 2002 (POCA) (concealing, arranging, or acquiring, using, or possessing criminal property) and offences relating to terrorist property under the Terrorism Act 2000. This policy is designed to help us avoid inadvertently committing such offences and to support voluntary, protective reporting to the National Crime Agency (NCA) where appropriate.

Limitless Capital takes a zero-tolerance approach to money laundering and terrorist financing. We are committed to:

• Applying proportionate customer due diligence appropriate to our business
• Screening customers against relevant financial sanctions lists
• Monitoring for transaction patterns or behaviour that may indicate suspicious activity
• Escalating concerns internally to our Money Laundering Reporting Officer (MLRO)
• Making voluntary disclosures to the National Crime Agency where appropriate
• Maintaining appropriate records
• Training staff to recognise and escalate potential concerns
• Declining to do business with individuals, entities, or jurisdictions subject to applicable sanctions

We screen customers against applicable financial sanctions lists before establishing a business relationship, and on an ongoing basis, including:

• The UK Office of Financial Sanctions Implementation (OFSI) Consolidated List of Financial Sanctions Targets
• The United Nations Security Council Consolidated List
• The US Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List, where relevant to our payment providers or Broker Partner

Rather than maintain a fixed list of prohibited countries in this policy, which can quickly become outdated as sanctions regimes change, we screen against the live official lists above and apply the current OFSI list of countries subject to comprehensive UK financial sanctions at the time a business relationship is considered. Any confirmed or potential match identified through screening is escalated to the MLRO and investigated before any business relationship proceeds or continues.

Where a jurisdiction becomes subject to comprehensive UK sanctions, or where a customer or transaction is connected to a sanctioned party, we will decline to establish, or will terminate, the business relationship as required by law.

All staff must report any activity or circumstances that raise concern to our Money Laundering Reporting Officer immediately. Potentially suspicious activity includes, but is not limited to:

• Unusual transaction patterns or volumes with no apparent legitimate purpose
• Customers who are reluctant or unable to provide requested identification information
• Transactions or enquiries connected to sanctioned individuals, entities, or jurisdictions
• Use of multiple accounts, identities, or payment methods without reasonable explanation
• Attempts to structure payments to stay below internal or regulatory thresholds

Where our MLRO determines it is appropriate, we will make a voluntary disclosure (Suspicious Activity Report) to the National Crime Agency, and will not notify the customer that a report has been made or is being considered.

We retain customer identification records, transaction records, risk assessments, and related compliance records for a minimum of five years from the end of the business relationship or the date of the last transaction, whichever is later, unless a longer period is required by law.

Relevant staff receive training on this policy upon joining Limitless Capital and periodically thereafter, covering how to recognise potential money laundering or sanctions concerns, our internal escalation procedure, and record-keeping requirements.

We periodically assess the money laundering, terrorist financing, and sanctions risks relevant to our business, having regard to our customer base, products and services, delivery channels, and the geographic reach of our business. Our procedures are reviewed and adjusted in light of this assessment.

We apply appropriate due diligence to our Broker Partner, payment processors, and other material third-party service providers, to satisfy ourselves that they maintain controls appropriate to their own regulatory obligations.

This policy is reviewed at least annually, and additionally where our services, risk profile, or the applicable legal and regulatory landscape change materially. Updates are communicated to relevant staff.

Failure by staff to comply with this policy may result in disciplinary action, up to and including termination of employment. Failure by a customer to comply with our due diligence requests, or confirmed involvement in suspected money laundering, terrorist financing, or sanctions evasion, may result in termination of the business relationship and reporting to the relevant authorities.

Questions or concerns regarding this policy, or reports of suspicious activity, should be directed to our Money Laundering Reporting Officer: