Anti-Money Laundering Policy

Effective: 1 March 2026

1. Policy Statement

Zavara Holdings LLC ("Zavara") is committed to the prevention of money laundering and the combating of terrorist financing. Although Zavara operates as a software vendor and does not handle, custody or transmit counterparty funds, we maintain robust anti-money laundering ("AML") procedures as part of our commitment to ethical business conduct and regulatory compliance.

2. Scope

This policy applies to all officers, employees and contractors of Zavara. It governs our approach to counterparty due diligence, risk assessment and the reporting of suspicious activity in connection with our software licensing operations.

3. Know Your Counterparty (KYC)

Before entering into a software licence engagement, Zavara conducts appropriate due diligence on prospective counterparties. This includes:

• Verifying the identity of the counterparty entity and its beneficial owners.
• Understanding the nature and purpose of the proposed business relationship.
• Assessing whether the counterparty or its principals appear on any sanctions lists or adverse media.
• Obtaining and retaining copies of relevant identification and corporate documents.

Enhanced due diligence is applied where the counterparty is assessed as presenting a higher risk, including counterparties based in jurisdictions identified as high-risk by the Financial Action Task Force (FATF).

4. Risk Assessment

Zavara maintains a risk-based approach to AML. We assess the money laundering and terrorist financing risks associated with each counterparty relationship, considering factors such as:

• The counterparty's jurisdiction of incorporation and operations.
• The nature of the counterparty's business and source of funds.
• The complexity and value of the engagement.
• The involvement of politically exposed persons (PEPs).

5. Ongoing Monitoring

We conduct ongoing monitoring of counterparty relationships to ensure that engagements remain consistent with our understanding of the counterparty's business. This includes periodic review of counterparty information and awareness of any changes in the counterparty's risk profile.

6. Suspicious Activity Reporting

All personnel are required to report any knowledge or suspicion of money laundering or terrorist financing to the designated Compliance Officer. Where appropriate, reports will be filed with the relevant authorities in accordance with applicable law.

Zavara strictly prohibits "tipping off" — informing any person that a suspicious activity report has been or may be filed.

7. Record Keeping

Zavara retains all KYC documentation, transaction records and correspondence related to counterparty due diligence for a minimum of five years following the conclusion of the business relationship, or longer if required by law.

8. Training

All Zavara personnel receive AML awareness training upon joining and periodically thereafter. Training covers the recognition of suspicious activity, reporting obligations and the consequences of non-compliance.

9. Sanctions Compliance

Zavara does not provide software or services to individuals or entities that are subject to sanctions imposed by the United Nations, the United States (OFAC), the European Union, HM Treasury or other relevant jurisdictions. Sanctions screening is conducted as part of the KYC process and on an ongoing basis.

10. Contact

For questions about this policy, contact us at:
Email: info@zavara.bz
Address: Suite 1D, 5827 Grad. Crescent & Bachelor Ave, Belize City, Belize