Client

Anti-Money Laundering (AML) & Know-Your-Client (KYC) Policy

Effective Date: August 9, 2025

Caraway Management (“Caraway,” “we,” “us,” or “our”) is committed to maintaining the highest standards of integrity and regulatory compliance. We have implemented robust Anti-Money Laundering (“AML”) and Know-Your-Client (“KYC”) procedures designed to prevent our services from being used for money laundering, terrorist financing, or other financial crimes.

Our policies are aligned with applicable laws and regulations in Japan, including the Act on Prevention of Transfer of Criminal Proceeds, as well as global best practices.

1. Policy Objectives

The primary objectives of our AML and KYC framework are to:

  • Prevent and detect money laundering and terrorist financing activities
  • Ensure compliance with all applicable legal and regulatory requirements
  • Safeguard the firm’s reputation and the integrity of financial markets
  • Establish a clear understanding of our clients and their financial activities

2. Risk-Based Approach

Caraway Management applies a risk-based approach to AML compliance. This involves:

  • Assessing the risk profile of each client at onboarding and on an ongoing basis
  • Considering factors such as jurisdiction, source of wealth, transaction patterns, and business activities
  • Applying enhanced due diligence (“EDD”) measures where higher risks are identified

3. Know-Your-Client (KYC) Procedures

We conduct thorough KYC checks prior to establishing any client relationship and periodically thereafter.

a. Client Identification

We verify the identity of all clients using reliable, independent documentation. This may include:

  • Government-issued identification (e.g., passport, national ID)
  • Proof of residential address
  • Corporate registration documents (for legal entities)

b. Beneficial Ownership

For corporate or legal entity clients, we identify and verify the ultimate beneficial owners (“UBOs”) who ultimately own or control the entity.

c. Purpose and Nature of Relationship

We obtain information regarding:

  • The purpose of the relationship
  • Expected account activity
  • Investment objectives and financial profile

d. Source of Funds and Wealth

We take reasonable steps to understand the origin of a client’s assets, including:

  • Income sources
  • Business activities
  • Investment history
Enhanced scrutiny may be applied in higher-risk situations.

4. Ongoing Monitoring

Client relationships are subject to continuous monitoring to ensure consistency with known profiles and risk assessments.

This includes:

  • Reviewing transactions and account activity
  • Updating client information periodically
  • Identifying unusual or suspicious patterns

5. Politically Exposed Persons (PEPs)

Caraway Management applies enhanced due diligence measures when dealing with Politically Exposed Persons (“PEPs”), their family members, or close associates.

This may include:

  • Additional identity verification
  • Senior management approval prior to onboarding
  • Increased monitoring of account activity

6. Sanctions Compliance

We screen clients against applicable sanctions lists and monitor updates to ensure ongoing compliance with international sanctions regimes.

We do not engage in business with individuals or entities subject to relevant sanctions.

7. Suspicious Activity Reporting

Where we identify or suspect illegal activity, we will take appropriate action, which may include:

  • Filing reports with relevant authorities in accordance with applicable laws
  • Restricting or terminating client relationships
  • Cooperating with regulatory and law enforcement agencies
Employees are trained to recognize and escalate suspicious activity promptly.

8. Record Keeping

We maintain records of:

  • Client identification and verification documents
  • Transaction history and account activity
  • Risk assessments and due diligence processes
Records are retained for the period required under applicable laws and regulations.

9. Staff Training and Compliance Oversight

Caraway Management ensures that:

  • Employees receive regular AML/KYC training
  • Compliance policies are reviewed and updated periodically
  • A designated compliance function oversees adherence to AML obligations

10. Third-Party Relationships

Where we rely on third-party intermediaries or service providers, we ensure that they maintain appropriate AML/KYC standards consistent with our own and applicable regulations.

11. Policy Review and Updates

This AML & KYC Policy is reviewed periodically to reflect changes in regulatory requirements and industry best practices.

12. Contact Information

For questions regarding this policy or our compliance framework, please contact:
Caraway Management
Tokyo, Japan
info@carawaymgmt.com

Caraway