1. Commitment and Scope

Globex Horizon Investment L.L.C. (Trade Licence No. 523059) operates as a private commercial enterprise under UAE Federal Commercial Law. We are committed to preventing our business from being used as a vehicle for money laundering, terrorist financing, or any other financial crime.

This policy applies to all employees, directors, agents, and partners of Globex Horizon, and to all commercial participation arrangements entered into by the company.

2. Legal Framework

Our AML/CFT programme is built on the requirements of:

• UAE Federal Law No. 20 of 2019 on Anti-Money Laundering and Combating the Financing of Terrorism
• Cabinet Decision No. 10 of 2019 on the Implementing Regulation of Federal Law No. 20 of 2019
• UAE Central Bank AML/CFT guidelines and circulars
• Financial Action Task Force (FATF) recommendations as adopted by the UAE

3. Know Your Customer (KYC) Requirements

Before entering into any commercial participation arrangement, Globex Horizon conducts due diligence on all prospective partners. The following documentation is required from all participants:

• Individual partners: Valid government-issued photo ID (passport or Emirates ID), proof of residential address (utility bill, bank statement — dated within 3 months), source of funds declaration
• Corporate partners: Certificate of incorporation, memorandum and articles of association, list of directors and shareholders, KYC documentation for all beneficial owners holding 25% or more, authorised signatory documentation

Enhanced due diligence is applied to Politically Exposed Persons (PEPs), high-risk jurisdictions, or where transactions present unusual characteristics.

4. Source of Funds

All partners are required to declare and provide documentation confirming the legitimate source of funds used for participation. Acceptable sources include employment income, business profits, sale of assets, inheritance, and similar verifiable origins. Funds from sources that cannot be adequately verified will not be accepted.

5. Suspicious Transaction Reporting

Globex Horizon has procedures in place to identify and report suspicious transactions or activities in accordance with UAE law. All employees are trained to recognise indicators of money laundering or terrorist financing and are required to escalate concerns through our internal reporting channels.

Suspicious activity reports (SARs) are submitted to the UAE Financial Intelligence Unit (FIU) via the goAML platform where required. Tipping off a subject of a SAR report is prohibited under UAE law.

6. Prohibited Transactions and Persons

Globex Horizon will not enter into any participation arrangement with:

• Individuals or entities on UAE, UN, EU, or US sanctions lists
• Individuals or entities from FATF high-risk or non-cooperative jurisdictions (subject to enhanced due diligence)
• Shell companies with no identifiable beneficial owner
• Any person where the source of funds cannot be adequately verified
• Any person where there are reasonable grounds to suspect involvement in criminal activity

7. Record Keeping

All KYC documentation, transaction records, and AML/CFT-related records are retained for a minimum of 5 years from the date of the relevant transaction or the end of the business relationship, whichever is later, in accordance with UAE law. Records are stored securely and made available to relevant authorities upon lawful request.

8. Training and Awareness

All Globex Horizon personnel who deal with partners or handle funds receive regular training on AML/CFT obligations, red flags, and internal reporting procedures. Training records are maintained and updated annually.

9. Compliance Officer

Globex Horizon has designated a Compliance Officer responsible for overseeing AML/CFT programme implementation, monitoring compliance, and maintaining the relationship with relevant regulatory and law enforcement authorities.

10. Cooperation with Authorities

Globex Horizon cooperates fully with UAE regulatory and law enforcement authorities. We provide requested information in a timely manner and do not obstruct any lawful investigation.

11. Policy Review

This AML Policy is reviewed and updated at least annually and whenever there are material changes to applicable laws or regulations.

12. Contact

AML/CFT enquiries: partner@globexhorizon.com · Office 511, Fairmont Hotel, Sheikh Zayed Road, Dubai, UAE. Trade Licence No. 523059 · Tax Registration No. 100291112900003.