CASE SG Limited · CSG-P-04

Anti-Money Laundering and Counterparty Screening Policy

Version 1.0 · Adopted by the board on 23 September 2026 · Next review 23 September 2027

All policies

Sets how the company identifies its counterparties and guards against money laundering and terrorist financing.

Scope

This policy applies to every counterparty with which the company enters a contractual or payment relationship, including buyers, suppliers, landowners, agents and advisers.

Know your counterparty

Before a relationship begins, the company obtains and records the counterparty's legal name, registration number, jurisdiction, registered address, ownership structure, and the identity of any beneficial owner holding more than 25 per cent.

Risk assessment

Each counterparty is assessed for risk by jurisdiction, ownership transparency, the nature of the transaction and the payment route. Higher-risk relationships require additional evidence and approval by a director.

Politically exposed persons

Where a counterparty, its owner or its beneficial owner is a politically exposed person, the relationship requires board approval and enhanced ongoing monitoring.

Payments

Funds are received only from and paid only to accounts in the name of the contracting counterparty. Third-party payments and payments to accounts in unrelated jurisdictions are refused unless approved by the board and documented.

Cash

The company does not accept or make payments in cash.

Records

Identification evidence and screening records are retained for at least seven years after the relationship ends.

Reporting

Any suspicion of money laundering is reported to a director immediately and, where required by law, to the relevant financial intelligence unit. The person who raised the suspicion must not alert the counterparty.

Reporting a concern

Concerns about any matter covered by this policy may be raised with any director or by email to compliance@inbox.case.sg. Reports made in good faith attract no adverse consequence.