This AML/KYC Policy sets out the anti-money laundering, counter-terrorism financing, and know-your-customer obligations of Liberty Platform PTY LTD in respect of the digital financial platform operated at libertystone.com.au.

Liberty Stone is registered with AUSTRAC as a reporting entity and is subject to the AML/CTF Act as a provider of designated financial services.

This Policy applies to all clients, prospective clients, and business relationships of the Platform.

Liberty Stone complies with the AML/CTF Act, the AML/CTF Rules, the Corporations Act 2001 (Cth), the Financial Transaction Reports Act 1988 (Cth), AUSTRAC regulatory guidance and compliance resources, and applicable sanctions regimes administered by DFAT and the United Nations Security Council.

Liberty Stone maintains a written AML/CTF Program (Version 1.0, adopted 20 March 2026) that meets the requirements of Part 7 of the AML/CTF Act.

The Program is reviewed at least annually, or following any material change in the nature, size, or complexity of our operations.

The Program comprises Part A, covering risk-based approach, customer due diligence, and transaction monitoring, and Part B, covering the customer identification program.

The AML/CTF Program is overseen by our designated AML/CTF Compliance Officer and has been adopted by the Board of Directors.

Before providing any designated service, Liberty Stone performs standard customer due diligence on all customers.

• Collection and verification of full legal name, date of birth, and residential address.
• Verification of identity against government-issued photographic identification via our approved identity verification partner.
• For corporate clients and SMSFs: verification of entity name, ABN or ACN, registered address, beneficial ownership, and trustee or director identity.
• Screening against government and international watchlists, sanctions lists, and PEP databases via our approved compliance screening partner.

Enhanced due diligence is applied where a customer or transaction presents a higher risk profile, including politically exposed persons and associates, customers from FATF high-risk jurisdictions, complex entity structures, and unexplained or inconsistent source of wealth.

Simplified due diligence may be applied where the risk of money laundering or terrorism financing is demonstrably low, in accordance with AUSTRAC guidelines and our internal risk assessment framework.

Identity verification is conducted using our approved identity verification partner.

• Document capture and OCR of government-issued identity documents.
• Biometric facial matching and liveness detection.
• Electronic database verification against Australian government records.
• Real-time watchlist and sanctions screening via our approved compliance screening partner.
• All identity verification results are recorded and retained in accordance with AML/CTF record-keeping obligations.

Liberty Stone conducts ongoing monitoring of customer accounts and transactions throughout the business relationship.

• Real-time and periodic transaction monitoring against defined risk-based rules and thresholds.
• Review of transactions for consistency with the customer's known profile, source of funds, and declared purpose.
• Periodic refresh of customer due diligence information aligned to risk rating.
• Automated continuous screening against updated watchlists, sanctions databases, and adverse media via our approved compliance screening partner.
• All alerts are triaged, investigated, and documented by the AML/CTF Compliance Officer.

Where our compliance team identifies a transaction or activity that gives rise to a reasonable suspicion of money laundering, terrorism financing, sanctions evasion, or other prohibited conduct, we are obligated to submit a Suspicious Matter Report to AUSTRAC.

Liberty Stone maintains a zero-tolerance approach to interference with the SMR process.

In accordance with tipping-off provisions, we are prohibited from disclosing to a customer or third party that an SMR has been or may be submitted.

Liberty Stone does not accept or pay physical cash under any circumstances. All transactions are conducted electronically, and accordingly no Threshold Transaction Reports are required or generated.

Liberty Stone does not provide services to individuals or entities subject to Australian sanctions, United Nations Security Council sanctions, or other applicable international sanctions regimes.

Our automated screening systems check all customers and transactions against applicable sanctions lists maintained by DFAT and other authoritative bodies.

In the event of a potential sanctions match, accounts will be frozen and the matter escalated to our Compliance Officer immediately.

Liberty Stone maintains records of all customer due diligence information, transaction records, and compliance decisions in accordance with the AML/CTF Act for a minimum of 7 years following the end of the relevant business relationship or completion of the relevant transaction.

All personnel who deal with customers, process transactions, or have AML/CTF responsibilities receive mandatory training on joining Liberty Stone and annually thereafter.

Training covers the AML/CTF Act, suspicious activity indicators, and internal reporting procedures.

Oversight of this Policy and the broader AML/CTF Program is the responsibility of the designated AML/CTF Compliance Officer, Stanley Drummond.

The Director reviews compliance performance on a regular basis and receives periodic AML/CTF reporting.

• Compliance Officer — Liberty Platform PTY LTD
• Email: compliance@libertystone.com.au
• This Policy was last updated on 20 March 2026.