Anti-Money Laundering Statement

Effective Date: April 2026

Ladd & Co. ("the firm") is committed to the prevention of money laundering, terrorism financing, sanctions evasion, bribery and corruption, tax evasion, and other financial crime. The firm operates a risk-based anti-money laundering ("AML"), counter-terrorism financing ("CTF"), and sanctions compliance framework that reflects the international nature of its practice and the sophistication of its client base.

This Statement summarises the firm's approach. It is not a comprehensive description of the firm's internal policies, procedures, and controls, which are maintained in confidence. The firm does not, by publishing this Statement, hold itself out as a regulated financial services provider; the firm's regulatory status is set out in the Legal Entity Disclosure.

1. Standards Applied

The firm's AML, CTF, and sanctions framework is informed by:

the recommendations of the Financial Action Task Force (FATF);
the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (Australia) and its associated rules, to the extent applicable;
the AML/CTF regimes of the other jurisdictions in which the firm operates or in which clients are based, including the United Kingdom, the European Union, the United States, the United Arab Emirates, Switzerland, Singapore, Hong Kong, and the Cayman Islands;
sanctions regimes administered by the Australian Department of Foreign Affairs and Trade (DFAT), the United States Office of Foreign Assets Control (OFAC), the United Kingdom Office of Financial Sanctions Implementation (OFSI), the European Union, and the United Nations Security Council;
relevant anti-bribery and corruption legislation, including the Australian Criminal Code, the U.S. Foreign Corrupt Practices Act (FCPA), and the U.K. Bribery Act 2010.

2. Risk-Based Approach

The firm applies a risk-based approach to AML, CTF, and sanctions compliance. The level of due diligence and ongoing monitoring applied to a client, counterparty, or matter is calibrated to the financial crime risk presented by the relationship, taking into account factors including:

the nature, structure, and beneficial ownership of the client;
the source of wealth and source of funds connected to the relationship;
the jurisdictions involved, including their financial crime risk profile;
the nature and economic substance of the engagement;
the involvement of politically exposed persons (PEPs), high-risk countries, or sanctioned parties;
any adverse media or other intelligence relevant to the relationship.

3. Client Due Diligence

Before entering into any engagement, the firm undertakes client due diligence appropriate to the assessed risk. This may include:

identification and verification of the client and, where applicable, of beneficial owners, controllers, and authorised representatives;
understanding the ownership and control structure of corporate, trust, and other non-individual clients;
identification of any politically exposed person status (whether of the client or a connected person);
screening against sanctions lists, PEP databases, adverse media sources, and law enforcement watchlists;
understanding the source of wealth and source of funds for the relationship;
understanding the purpose and intended nature of the engagement.

The firm reserves the right to request such information and documentation as it considers necessary to satisfy its due diligence requirements, and to decline to proceed with any prospective engagement where adequate information cannot be obtained or where the assessed risk is unacceptable.

4. Enhanced Due Diligence

Enhanced due diligence is applied where:

the client, beneficial owner, or a connected person is a politically exposed person, family member of a PEP, or close associate of a PEP;
the client, counterparty, or matter has a connection to a high-risk jurisdiction;
the engagement involves complex or unusually structured arrangements without an apparent economic or lawful purpose;
adverse information is identified through screening or in the course of due diligence; or
the firm otherwise determines that the financial crime risk warrants additional scrutiny.

Enhanced due diligence may involve additional information requests, independent verification of source of wealth and source of funds, senior management approval of the relationship, and increased ongoing monitoring.

5. Sanctions Compliance

The firm does not knowingly establish or maintain relationships with parties subject to applicable sanctions or other restrictive measures. The firm undertakes sanctions screening at the onboarding of clients and counterparties and on an ongoing basis throughout an engagement.

Where a sanctions concern is identified during the course of an engagement, the firm will take action consistent with applicable law, which may include suspending services, terminating the engagement, freezing relevant transactions, and making notifications to relevant authorities where required.

6. Ongoing Monitoring

The firm conducts ongoing monitoring of client relationships and engagements proportionate to the risk presented, including:

periodic review of client information and risk classification;
ongoing screening against updated sanctions, PEP, and adverse media data;
review of unusual or unexpected activity arising in the course of an engagement;
periodic refresh of due diligence information.

7. Reporting and Escalation

The firm will make reports to relevant authorities where required by applicable law, including suspicious matter or suspicious activity reports under applicable AML/CTF legislation. Where the firm makes such a report, it does so on a confidential basis and may be prohibited from disclosing the existence of the report to the affected client or any other person ("tipping off").

The firm has internal escalation procedures for personnel to raise financial crime concerns to designated senior individuals.

8. Anti-Bribery and Corruption

The firm prohibits bribery and corruption in all forms. The firm does not offer, give, solicit, or accept bribes, kickbacks, facilitation payments, or any other improper payment or benefit. The firm's personnel are required to comply with the firm's anti-bribery and corruption standards in all interactions with public officials, clients, counterparties, intermediaries, and service providers.

The firm exercises particular care in connection with:

gifts, hospitality, and entertainment;
payments to or arrangements with intermediaries, agents, and consultants;
charitable and political contributions;
engagements involving public officials, state-owned entities, or jurisdictions presenting elevated corruption risk.

9. Tax Compliance

The firm does not assist or advise clients in respect of arrangements designed to facilitate tax evasion. International tax structuring services are provided in the context of legitimate cross-border planning, the management of multi-jurisdictional compliance obligations, and the lawful organisation of clients' affairs.

The firm complies with applicable obligations relating to the prevention of the facilitation of tax evasion, including under the U.K. Criminal Finances Act 2017 to the extent applicable.

10. Personnel and Training

Personnel of the firm are trained on AML, CTF, sanctions, anti-bribery, and related financial crime topics appropriate to their role. The firm conducts background screening on personnel as part of its onboarding processes.

11. Record-Keeping

The firm maintains records of due diligence information, screening results, transaction documentation, and other AML/CTF-related records for the periods required under applicable law, and in any event for a minimum of seven years following the termination of the relevant relationship or transaction.

12. Cooperation with Authorities

The firm cooperates with law enforcement, regulatory, and tax authorities in accordance with applicable law and the firm's professional obligations. The firm responds to lawful requests for information promptly, while ensuring that responses are made through appropriate channels and on a basis consistent with the firm's confidentiality obligations.

13. Limitation

This Statement is provided for general information. It does not create any rights, obligations, or representations in favour of any client, counterparty, or third party. The terms on which the firm provides services to any specific client are set out in the relevant engagement agreement.

14. Contact

For questions regarding the firm's AML, CTF, sanctions, or financial crime framework, please contact:

Ladd & Co. Email: office@laddco.com Website: laddco.com

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