1. Purpose and Commitment

Investra International Ltd is committed to preventing the use of the Investra platform for money laundering, terrorist financing, sanctions evasion or other financial crime. This Policy summarises the framework we apply, aligned with the FATF Recommendations, applicable EU anti-money-laundering directives and regulations, and the national laws of the markets in which we operate.

This public summary is provided for transparency; internal procedures contain the operative detail and prevail in case of divergence.

2. Scope

The Policy applies to all users and Partners of the Platform, to all employees and contractors of Investra, and to all products and services offered through the Platform, including reservations and deposit handling in cooperation with licensed payment institutions.

3. Governance

The board has appointed a Money Laundering Reporting Officer (MLRO) responsible for oversight of this framework, staff training, and reporting to competent authorities. Compliance staff operate independently of commercial teams and have unrestricted access to records required for their duties.

4. Customer Due Diligence

Before establishing a business relationship we identify and verify customers using reliable, independent sources, including electronic identity verification and document checks. For corporate customers we identify beneficial owners holding, directly or indirectly, more than 25% of shares or voting rights, and verify their identity on a risk-sensitive basis.

We apply simplified measures only where a documented risk assessment permits, and enhanced measures for higher-risk situations, including politically exposed persons, complex ownership structures and customers connected to higher-risk jurisdictions identified by the FATF or the European Commission.

5. Ongoing Monitoring

We monitor business relationships on an ongoing basis, including scrutiny of transactions for consistency with our knowledge of the customer, periodic refresh of due-diligence data, and screening of customers and Partners against sanctions and watch lists at onboarding and on a recurring basis.

6. Reporting of Suspicious Activity

Employees must report suspicions of money laundering or terrorist financing to the MLRO, who assesses and, where required, files reports with the competent financial intelligence unit without tipping off the customer. We fully cooperate with law-enforcement and supervisory authorities within the limits of applicable law.

7. Record Keeping

We retain due-diligence records and transaction documentation for the statutory period of the relevant market:

Longer retention applies where required by national law or a competent authority.

8. Training

All relevant staff receive AML training at onboarding and at least annually, covering typologies relevant to real estate, red flags, sanctions and internal reporting channels. Training completion is tracked and enforced.

9. Real-Estate Specific Measures

Real estate carries elevated laundering risk. We apply source-of-funds checks for reservation deposits above thresholds defined in internal procedures, heightened scrutiny of third-party payments, and verification that Partner escrow arrangements comply with the client-money rules of the relevant market, including EU member states and the TRNC.

10. Sanctions Compliance

We do not establish or continue relationships with persons or entities subject to applicable sanctions of the UN, EU or UK, or where a relationship would breach other sanctions regimes applicable to us. Assets and transactions are frozen or rejected where required by law.

11. Consequences of Non-Compliance

We may delay, restrict or refuse transactions, suspend Accounts and terminate relationships where required by this framework. To the extent permitted by law, we accept no liability for loss caused by measures taken in good faith under this Policy.