• AML & KYC Policy

ANTI-MONEY LAUNDERING (AML) & KNOW YOUR CUSTOMER (KYC) POLICY

Elysium Management Company
(United States & South Africa)

Effective Date: 27th Feburary 2026
Last Updated: 27th Feburary 2026

1. Purpose

Elysium Management Company (“Elysium,” “Company,” “we,” or “us”) is committed to preventing money laundering, terrorist financing, fraud, corruption, and other financial crimes.

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines the procedures implemented to:

  • Verify customer identity

  • Prevent unlawful use of our services

  • Comply with applicable laws in the United States and South Africa

  • Mitigate financial and reputational risk

This policy applies to all purchasers of Elysium Membership Packages and all individuals receiving equity allocations.

2. Regulatory Framework

Elysium operates in compliance with applicable laws, including but not limited to:

🇺🇸 United States

  • Bank Secrecy Act (BSA)

  • USA PATRIOT Act

  • Office of Foreign Assets Control (OFAC) regulations

🇿🇦 South Africa

  • Financial Intelligence Centre Act (FICA)

  • Protection of Constitutional Democracy Against Terrorist and Related Activities Act

  • POPIA (for data protection compliance)

Where cross-border transactions occur, we apply enhanced due diligence standards.

3. Customer Identification (KYC Requirements)

Before issuing equity or activating certain benefits, Elysium may require verification of identity.

Individuals may be required to provide:

  • Full legal name

  • Date of birth

  • Nationality

  • Government-issued identification (passport, ID card, or driver’s license)

  • Proof of residential address (utility bill or bank statement)

  • Tax identification number (where applicable)

Corporate Entities (if applicable):

  • Certificate of incorporation

  • Registered address

  • Director identification

  • Beneficial ownership disclosure

  • Corporate structure documentation

Elysium reserves the right to request additional documentation where necessary.

4. Source of Funds Verification

Where appropriate, Elysium may request documentation to verify the lawful origin of funds used to purchase membership packages or equity allocations.

This may include:

  • Bank statements

  • Proof of income

  • Declaration of source of funds

  • Business ownership documentation

Failure to provide satisfactory documentation may result in refusal of service.

5. Sanctions & Watchlist Screening

Elysium may screen customers against:

  • OFAC sanctions lists (USA)

  • United Nations sanctions lists

  • South African sanctions directives

  • Politically Exposed Persons (PEP) databases

  • International financial crime watchlists

If a match or potential match is identified, Elysium reserves the right to:

  • Suspend the transaction

  • Request additional documentation

  • Report to relevant authorities

  • Refuse membership or share allocation

6. Ongoing Monitoring

Elysium may conduct periodic reviews of:

  • Shareholder records

  • High-value transactions

  • Suspicious activity indicators

Where suspicious activity is identified, we may:

  • File Suspicious Activity Reports (SARs) where required

  • Cooperate with regulatory authorities

  • Freeze or restrict services where legally permitted

7. Risk-Based Approach

Elysium applies a risk-based approach to AML compliance, considering:

  • Country of residence

  • Transaction size

  • Frequency of transactions

  • Complexity of ownership structures

  • Equity participation

Higher-risk profiles may require Enhanced Due Diligence (EDD).

8. Refusal or Termination of Services

Elysium reserves the right to:

  • Refuse membership or equity issuance

  • Delay transactions pending verification

  • Terminate services

  • Withhold benefits where compliance obligations are not satisfied

No explanation may be provided where disclosure would violate applicable law.

9. Record Keeping

In compliance with regulatory requirements, Elysium maintains records of:

  • Identity verification documents

  • Transaction records

  • Shareholder registers

  • Compliance communications

Records may be retained for a minimum of 5–10 years as required by applicable laws.

10. Data Protection

All personal data collected for AML/KYC purposes is processed in accordance with:

  • Elysium’s Privacy Policy

  • POPIA (South Africa)

  • Applicable U.S. data protection standards

Information is stored securely and accessed only by authorized personnel.

11. Reporting Obligations

Elysium may report suspicious activities to:

  • Financial Intelligence Centre (South Africa)

  • U.S. Financial Crimes Enforcement Network (FinCEN)

  • Other competent regulatory authorities

Members acknowledge that reporting obligations may override confidentiality in cases required by law.

12. Acceptance of Policy

By purchasing a Membership Package and/or accepting equity allocation, you acknowledge:

  • You may be subject to identity verification

  • Your information may be screened against sanctions databases

  • Transactions may be delayed or declined for compliance reasons

Failure to comply with AML/KYC requirements may result in cancellation of participation.