FATF AML/CFT Statement

1. Our Commitment to Financial Integrity

ABR First Capital, LLC and ABR Capital Funding LLC (collectively "the Companies") are unconditionally committed to preventing our platforms from being used for money laundering, terrorist financing, proliferation financing, fraud, corruption, or any other financial crime.

We maintain a comprehensive AML/CFT compliance program designed and implemented in accordance with:

• The Bank Secrecy Act (BSA) and regulations promulgated thereunder (31 CFR Chapter X);
• The USA PATRIOT Act (Title III — International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001);
• FinCEN's Customer Due Diligence Rule (31 CFR Part 1010);
• OFAC sanctions regulations and guidance;
• The 40 Recommendations of the Financial Action Task Force (FATF) as updated through 2023;
• Applicable Texas state laws and regulations.

This statement is published in the spirit of transparency and in accordance with best practices for non-bank financial intermediaries handling investor funds.

2. Governance & Program Oversight

Senior management of the Companies bears ultimate responsibility for the adequacy and effectiveness of our AML/CFT compliance program. A designated Compliance Officer (or equivalent senior officer) holds day-to-day responsibility for:

• Maintaining and updating the written AML program;
• Supervising KYC/CDD procedures;
• Overseeing transaction monitoring and SAR filing;
• Coordinating regulatory examinations and inquiries;
• Ensuring timely AML training of all relevant personnel.

The AML program is reviewed and updated at least annually, or more frequently when material changes occur in applicable law, regulatory guidance, or business operations. Independent review of the program is conducted periodically to test its effectiveness.

3. Risk-Based Approach & ML/TF Risk Assessment

Consistent with FATF Recommendation 1, the Companies apply a risk-based approach to AML/CFT compliance. We have conducted, and periodically update, a written Money Laundering and Terrorist Financing (ML/TF) Risk Assessment that considers:

• Customer risk: Investor type, country of residence, politically exposed person status, occupation, source of wealth;
• Geographic risk: Jurisdictions identified as high-risk by FATF, FinCEN, OFAC, or the Companies' own analysis;
• Product/service risk: Risk inherent in private placement securities, promissory notes, and invoice financing;
• Channel risk: How investors are introduced (direct, referral, etc.).

Risk ratings (Low, Medium, High) are assigned to each investor relationship and determine the level of due diligence applied. Higher-risk relationships are subject to enhanced scrutiny and more frequent review.

4. Customer Identification Program (CIP)

Consistent with 31 CFR § 1023.220 and FATF Recommendation 10, the Companies maintain a written Customer Identification Program (CIP). Prior to accepting any investment, we collect and verify the following minimum information for each investor:

Individual Investors

• Full legal name;
• Date of birth;
• Residential address (no P.O. boxes for primary address);
• Social Security Number or Individual Taxpayer Identification Number;
• Government-issued photo identification (driver's license, passport, or other accepted document).

Entity Investors

• Legal entity name and type;
• Principal place of business address;
• Employer Identification Number (EIN) or foreign equivalent;
• Certified organizational documents (articles of incorporation, operating agreement, trust agreement, etc.);
• Beneficial ownership information (see CDD section below);
• Identification of controlling persons (signatories, managing members, trustees, etc.).

Identification documents are verified through documentary and/or non-documentary methods, including comparison against government databases, credit bureau records, and third-party identity verification services where appropriate. We reserve the right to require additional documentation at any time.

5. Customer Due Diligence (CDD)

Consistent with FinCEN's CDD Rule (31 CFR § 1010.230) and FATF Recommendation 10, we conduct Customer Due Diligence for all investors, including:

Beneficial Ownership

For legal entity investors, we identify and verify the identity of all natural persons who own 25% or more of the equity interest and at least one individual who exercises significant control or management authority over the entity (the "control prong"). Beneficial ownership information is collected on our standard Beneficial Ownership Certification Form.

Understanding the Customer Relationship

We collect information sufficient to understand the nature and purpose of each investor relationship, including:

• Source of investment funds (e.g., savings, business income, real estate sale, inheritance);
• Source of wealth (overall wealth accumulation);
• Investment objectives and anticipated investment activity;
• Business or occupation details for entity investors.

Ongoing Monitoring

Investor relationships are subject to ongoing monitoring throughout the investment term, including periodic review of investor information and monitoring of transactions for patterns inconsistent with the investor's known profile.

6. Enhanced Due Diligence (EDD)

Consistent with FATF Recommendation 19 and applicable U.S. guidance, Enhanced Due Diligence is applied to investor relationships assessed as higher-risk, including but not limited to:

• Investors who are Politically Exposed Persons (PEPs) or close associates of PEPs;
• Investors located in or associated with jurisdictions subject to FATF calls for action (blacklist/greylist) or FinCEN geographic targeting orders;
• Investors with unusual source of funds or wealth explanations;
• Investors who exhibit behaviors inconsistent with their stated profile;
• Investors involving complex entity structures with unclear beneficial ownership;
• Non-face-to-face relationships where identity verification is more challenging.

EDD measures may include: senior management approval for onboarding, third-party database checks, additional documentation requests, more frequent periodic reviews, and enhanced transaction monitoring.

7. Politically Exposed Persons (PEPs)

Consistent with FATF Recommendation 12, the Companies apply enhanced scrutiny to relationships involving Politically Exposed Persons — individuals who are or have been entrusted with a prominent public function, including:

• Heads of state or government, senior politicians;
• Senior government officials, judicial officials, or military officers;
• Senior executives of state-owned enterprises;
• Senior officials of political parties;
• Immediate family members and known close associates of the above.

For investors identified as PEPs:

• Senior management approval is required prior to onboarding;
• Enhanced source of wealth and source of funds verification is conducted;
• Ongoing enhanced monitoring is applied for the duration of the relationship;
• Former PEPs are treated with appropriate risk-based caution for a reasonable period following departure from public office.

PEP screening is conducted using reputable commercial screening databases at onboarding and on an ongoing basis.

8. Sanctions Compliance

The Companies maintain a robust sanctions compliance program to ensure no business is conducted with sanctioned individuals, entities, or jurisdictions. We screen all prospective and existing investors against:

• OFAC SDN List — Specially Designated Nationals and Blocked Persons;
• OFAC Consolidated Sanctions List — All OFAC-administered sanctions programs;
• UN Security Council Sanctions Lists;
• EU Consolidated Sanctions List;
• U.S. Department of Commerce Entity List and Denied Persons List;
• Other applicable watchlists.

Screening is conducted at onboarding and on an ongoing basis. Any positive matches are escalated to the Compliance Officer immediately. Investments from or involving sanctioned parties are blocked and reported to OFAC as required by law. We do not accept investments from individuals or entities located in comprehensively sanctioned jurisdictions (currently including Cuba, Iran, North Korea, Russia (certain sectors), Syria, and the Crimea, Donetsk, and Luhansk regions of Ukraine).

9. Transaction Monitoring

The Companies conduct ongoing monitoring of investor transactions and relationships to detect and report suspicious activity. Monitoring includes:

• Review of investment amounts, payment sources, and redemption patterns against the investor's known financial profile;
• Identification of transactions inconsistent with the stated purpose of the investment;
• Detection of structuring or layering patterns;
• Monitoring for unusual payment method changes or requests;
• Review of third-party payment requests (payments made to or from parties other than the registered investor).

All transactions are documented, and unusual activity is investigated promptly by the Compliance Officer.

10. Suspicious Activity Reporting

Where the Companies know, suspect, or have reason to suspect that a transaction involves funds derived from illegal activity, is designed to evade BSA reporting requirements, lacks a lawful purpose, or involves terrorist financing, we will file a Suspicious Activity Report (SAR) with FinCEN as required by applicable law.

SARs are filed within the time period required by law (generally 30 days of initial detection, or 60 days where no suspect can be identified). All SAR filings are treated as strictly confidential, and consistent with the law, we do not disclose to any person (including the subject of the SAR) that a SAR has been filed.

The Companies will not proceed with, or will terminate, any transaction or relationship where there are reasonable grounds to suspect money laundering or terrorist financing, even if no SAR is ultimately required.

11. Record Keeping

Consistent with FATF Recommendation 11 and BSA requirements, the Companies maintain complete and accurate records of:

• All investor identification and verification documentation;
• Beneficial ownership certifications;
• Due diligence files and supporting documentation;
• All investment transactions;
• SAR filings and supporting investigation records;
• CTR filings;
• AML training records;
• Independent review reports.

Records are retained for a minimum of five (5) years following the end of each investor relationship, in accordance with BSA requirements, and longer where required by applicable law. Records are maintained in a format that can be made available promptly to competent authorities upon lawful request.

12. Training & Awareness

All personnel with AML/CFT responsibilities receive regular training on:

• The Companies' AML program, policies, and procedures;
• Recognition of suspicious activity red flags;
• BSA reporting requirements (SARs, CTRs);
• OFAC sanctions compliance;
• Customer identification and due diligence procedures;
• Applicable legal obligations and consequences of non-compliance.

Training is provided at onboarding and at least annually thereafter, with refresher training when material regulatory changes occur. Training completion and assessment results are documented and retained.

13. Third-Party Relationships & Correspondent Banking

Where the Companies rely on third parties (such as referral agents, placement agents, or introducers) for customer introduction, we do not delegate our BSA/AML obligations. Third-party introducers are vetted for AML compliance standards before engagement. The Companies retain ultimate responsibility for ensuring adequate KYC/CDD is performed on all investor relationships, regardless of the introduction source.

The Companies do not maintain correspondent banking relationships with shell banks or financial institutions located in jurisdictions that do not require AML programs.

14. Tipping-Off Prohibition

Consistent with FATF Recommendation 21 and applicable U.S. law, the Companies and their personnel are strictly prohibited from "tipping off" any person — including any investor, counterparty, or third party — that a SAR has been filed, that an investigation is underway, or that law enforcement inquiries have been received. All AML investigations and regulatory reporting are treated as strictly confidential. Violations of the tipping-off prohibition may constitute a federal crime.

15. AML/CFT Contact & Reporting

Investors or counterparties with AML/CFT concerns, or who wish to report suspected financial crime, may contact our Compliance Officer:

Reporting Financial Crime to Authorities

Suspected financial crime may also be reported directly to:

• FinCEN: fincen.gov/report-financial-crime
• FBI Financial Crimes: ic3.gov
• OFAC (sanctions violations): ofac.treasury.gov
• SEC (securities fraud): sec.gov/tcr