AML and KYC Policy

Legal Entity: UKA$II LTD (trading as Rock 'n Roll CEO)
Company Registration Number: 11195881
Registered Office: 28 Cillocks Close, Hoddesdon, London, England
Effective Date: October 2026
Policy Owner / MLRO: Semra Erener

UKA$II LTD (trading as Rock 'n Roll CEO), hereinafter referred to as "the Company," is committed to the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. We operate a zero-tolerance policy towards financial crime, bribery, and corruption. This policy outlines our framework to prevent our commercial operations, AI automation, and cyber security services from being used to facilitate money laundering or any other financial crime, anywhere in the world.

As a UK-registered private limited company operating internationally (including Europe, UAE, and Turkey), this policy complies with the primary UK legislative framework and aligns with global FATF recommendations for international engagements:

• The Proceeds of Crime Act 2002 (POCA)
• The Terrorism Act 2000
• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)
• The Bribery Act 2010

The Company applies a Risk-Based Approach to all prospective and existing enterprise client relationships. Before finalizing any commercial engagement or embedding fractional executives, we assess the risk profile of the client based on:

• Customer Risk: The client's corporate structure, transparency of ownership, and industry sector.
• Geographic Risk: The jurisdictions in which the client is registered or operates.
• Service Risk: The nature of the fractional services provided and the level of access to the client’s financial, data, or strategic systems.

For all new corporate clients, UKA$II LTD executes a standard Know Your Business (KYB) and Know Your Customer (KYC) procedure prior to signing definitive commercial agreements.

Our standard CDD requires the collection and verification of:

• Corporate Identity: Certificate of Incorporation, Memorandum and Articles of Association, and proof of registered operating address.
• Operational Status: Verification that the entity is active and in good standing via official national registries.
• Ultimate Beneficial Ownership (UBO): Identification of all individuals who ultimately own or control 25% or more of the client’s shares or voting rights.
• Key Stakeholders: Identification of the primary directors and the authorized signatories executing the engagement contracts.

EDD measures are triggered automatically for engagements presenting a higher risk profile. This includes:

• Clients operating in, or with significant exposure to, high-risk third countries.
• Clients where the UBOs or key directors are identified as Politically Exposed Persons (PEPs) or close associates of PEPs.
• Complex corporate structures that obscure ultimate ownership.

EDD Measures include:

• Establishing the source of funds and source of wealth of the client/UBO.
• Requiring senior management approval before commencing the engagement.

No commercial relationship will be established with any entity or individual subject to international financial sanctions. We actively screen all corporate clients, their directors, and UBOs against the following consolidated watchlists:

• UK HM Treasury (OFSI)
• UN Security Council
• EU Consolidated List
• US OFAC (Office of Foreign Assets Control)

AML and KYC compliance is continuously monitored by:

• Periodically refreshing CDD documentation for long-term embedded fractional leadership roles.
• Monitoring the relationship for sudden, unexplained changes in corporate structure or payment methods.
• Re-screening clients against updated sanctions and PEP lists globally.

All fractional executives, partners, and contractors representing UKA$II LTD must remain vigilant for red flags.

• Any suspicion of money laundering or financial crime must be reported immediately to the internal Money Laundering Reporting Officer (MLRO), Semra Erener.
• The MLRO is responsible for evaluating the internal report and submitting a Suspicious Activity Report (SAR) to the UK National Crime Agency (NCA) if deemed necessary.
• Under no circumstances will the client be informed ("tipped off") that a report has been made.

In compliance with UK MLR and UK GDPR, UKA$II LTD retains all CDD/EDD records, identification documents, risk assessments, and transaction histories for a strict period of five (5) years following the termination of the business relationship. Data is stored securely and used solely for the purpose of AML/CTF compliance.