Anti-Money Laundering Policy

Section 1

Policy Statement & Commitment

Long Term Developments Ltd maintains a zero-tolerance approach to money laundering, terrorist financing, and any financial crime. This is not merely a regulatory obligation — it reflects the standards expected of a UK-registered fund operating in international capital markets and seeking the confidence of sophisticated and high-net-worth investors.

We are committed to full compliance with 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), and all related UK legislation. Every individual acting on behalf of Long Term Developments Ltd — including principals, agents, and appointed intermediaries — is bound by this policy.

Any breach of this policy is treated as a serious matter and may result in termination of an engagement, referral to the relevant authorities, or both.

Section 2

Scope of This Policy

This policy applies to all business relationships entered into by Long Term Developments Ltd, including prospective investors making enquiries, confirmed participants in the fund, and any professional counterparties, introducers, or service providers with whom the company transacts.

The policy applies from first contact. Where an individual or entity is unable or unwilling to satisfy our due diligence requirements, Long Term Developments Ltd will decline to proceed with the relationship.

Section 3

Risk Assessment

We conduct a documented risk assessment before entering any new business relationship. This assessment considers:

• The nature and source of funds being introduced
• The jurisdiction from which the investor or counterparty operates
• The complexity of the ownership structure (including any trust or corporate layering)
• Whether the individual or entity appears on any sanctions list or is classified as a Politically Exposed Person (PEP)
• Any other factor that, in our judgement, increases the risk of financial crime

Risk assessments are reviewed periodically and whenever material changes occur in a client relationship or the broader regulatory environment.

Section 4

Customer Due Diligence (CDD) and Identity Verification

All prospective investors and counterparties are required to complete Customer Due Diligence before any business relationship is established. Standard CDD includes verification of identity and address, confirmation of source of funds, and confirmation of source of wealth where required.

We use a formal Proof of Identity Checklist to structure this process consistently. Acceptable identity documents are verified against original or certified copies and recorded in accordance with our document retention obligations.

Where a higher-risk profile is identified — for example, a PEP, a complex ownership structure, or a counterparty based in a jurisdiction identified as higher risk by FATF — we apply Enhanced Due Diligence (EDD). This may include senior management approval, additional documentation, and more frequent monitoring of the relationship.

Simplified Due Diligence is applied only where permitted under the 2017 Regulations and where the risk assessment supports it.

Section 5

Ongoing Monitoring

Customer due diligence is not a one-time exercise. Long Term Developments Ltd monitors existing business relationships on an ongoing basis to ensure that transactions are consistent with our knowledge of the client, their stated source of funds, and the expected nature of the relationship.

CDD documentation is kept up to date. Where a client's circumstances change — including changes in beneficial ownership, jurisdiction, or the nature of the funds involved — we will require updated documentation before continuing the relationship.

Section 6

Reporting Suspicious Activity

All principals and staff of Long Term Developments Ltd are required to report any knowledge or suspicion of money laundering or terrorist financing to the nominated Money Laundering Reporting Officer (MLRO) as soon as reasonably practicable.

Where the MLRO determines that a report is warranted, a Suspicious Activity Report (SAR) will be submitted to the National Crime Agency (NCA) in accordance with Part 7 of the Proceeds of Crime Act 2002. No transaction subject to a SAR will proceed without consent from the NCA, or until the consent period has elapsed as provided by law.

Tipping off — that is, disclosing to any person that a SAR has been made or that an investigation is underway — is a criminal offence. Any person bound by this policy is expressly prohibited from doing so.

Section 7

Record Keeping

We retain all CDD documentation, transaction records, and internal reports for a minimum of five years from the date the business relationship ends, or from the date of an occasional transaction, whichever is later. Records are stored securely and are available for inspection by the relevant regulatory authority upon request.

Section 8

Training and Awareness

All individuals acting on behalf of Long Term Developments Ltd who are involved in client-facing activities or financial transactions receive regular training on their AML obligations. This training covers the recognition of suspicious activity, the correct process for internal reporting, and the legal consequences of non-compliance.

This policy is reviewed at least annually and updated as necessary to reflect changes in legislation, regulatory guidance, or the company's own risk profile.

Section 9

Demonstrating Compliance to Clients and Regulators

We understand that clients — particularly sophisticated and high-net-worth investors conducting allocations rather than speculation — require evidence that the vehicle they are entering is governed to institutional standards. Long Term Developments Ltd demonstrates compliance through:

• A documented and consistently applied CDD process, anchored by our Proof of Identity Checklist
• A clear internal escalation path from frontline staff to the MLRO
• Timely SAR reporting to the NCA where required
• Retained records accessible to regulators on request
• Annual policy reviews aligned to current UK AML legislation and FATF guidance

We are committed to making this framework visible to prospective investors as part of the broader due diligence conversation. If you have questions about our compliance procedures in the context of your own investment decision, please contact us or request an investor pack.