This policy confirms Futswap Markets Kommanditbolag’s commitment to preventing money laundering and terrorism financing in its business practices and transactions. Money laundering refers to the process of disguising the financial proceeds of criminal activities to conceal their illegal origin. Terrorism financing is defined as any financial support provided to those attempting to promote, plan, or engage in terrorist activities.

Our Head of Compliance is responsible for developing and implementing this policy and relevant procedures. Futswap Markets Kommanditbolag is committed to reviewing its Know Your Customer (KYC) policies and procedures annually to ensure they comply with current regulations.

To support our KYC policy and procedures, Futswap Markets Kommanditbolag utilizes advanced tools developed specifically for conducting KYC checks. These tools are sent to all our clients to collect the necessary business information to identify and assess money laundering risks. We require the KYC form to be completed by all new and existing clients.

By collecting and reviewing the information provided in the completed KYC forms, Futswap Markets Kommanditbolag commits to:

• Establishing the identity of our clients and counterparties.
• Verifying that our counterparties are not considered high-risk (this includes checking whether counterparties are located in high-risk jurisdictions identified by the FATF (Financial Action Task Force), listed on government-sponsored watchlists, international (UN) sanctions lists, or if they source from conflict-affected and high-risk areas (CAHRAs)).
• Maintaining a clear understanding of the nature and legitimacy of all our counterparties’ businesses.
• Retaining KYC records for a minimum of five years, in accordance with applicable laws and regulations.
• Keeping records of all single or linked cash (or cash-like) transactions above 10,000 EUR.
• Monitoring transactions for unusual or suspicious activity, which could result in the counterparty being considered high-risk.

If counterparties are deemed high-risk for any reason (for example, being listed on a sanctions list or engaging in unusual activity), Futswap Markets Kommanditbolag may take the following actions:

• Terminate the relationship with the counterparty immediately.
• Identify the beneficial owners of the counterparty and check whether those beneficial owners are on any watchlists or sanctions lists.
• Implement Enhanced Due Diligence (EDD) measures, which may include more rigorous monitoring of the counterparty’s transactions and activities.

Our comprehensive approach to preventing money laundering and terrorism financing is based on risk assessment, continuous due diligence, and compliance with international and Swedish regulations. In addition, we maintain a mandatory and periodic training program for all employees to ensure they are informed and equipped to meet their legal obligations.

Futswap Markets Kommanditbolag will periodically review and update this policy and all related procedures in accordance with changes in applicable laws and international best practices, ensuring continuous improvement in regulatory compliance.