Policy

AML / KYC / Sanctions

Effective: April 2026 Owner: Chief Compliance Officer Applies to: All Telvo entities

Framework

Telvo maintains an anti-money laundering (AML), know-your-customer (KYC), and sanctions screening program applicable to all LP investors, carrier counterparties, property counterparties, and material vendor relationships across the platform.

Investor Onboarding

LP subscription is contingent upon completion of KYC documentation including entity formation documents, beneficial ownership certifications, source of funds representations, and OFAC sanctions screening. Enhanced due diligence is applied to LPs from higher-risk jurisdictions or with elevated PEP exposure.

Ongoing Monitoring

Sanctions screening is refreshed on a rolling basis for existing LPs and material counterparties. Subscription documents include ongoing certification obligations for changes in beneficial ownership or sanctions status.

Suspicious Activity

Telvo maintains a suspicious activity escalation procedure. Any suspected AML or sanctions violation is escalated to the Chief Compliance Officer and reported to regulatory authorities as required by law.