Our Commitment to Compliance

First Brick Capital Fund (“we”, “our”, “us”) is fully committed to complying with all applicable Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know Your Customer (KYC) regulations.
We maintain strict internal controls, due diligence procedures, and monitoring systems to prevent illicit activities and ensure transparency in all financial operations.

Our compliance framework aligns with international standards, including:

FATF (Financial Action Task Force) recommendations

EU AML Directives

US OFAC and FinCEN guidelines (where applicable)

Local regulatory requirements relevant to jurisdictions in which we operate

1. Customer Due Diligence (CDD)

Before entering into any financial or business relationship, First Brick Capital Fund performs mandatory Customer Due Diligence, which includes:

• Verification of identity (individuals and corporate entities)
• Verification of beneficial ownership structure
• Collection of legally required documentation
• Assessment of the purpose and intended nature of the relationship
• Screening against international sanctions, PEP (Politically Exposed Persons) lists, and watchlists
• Enhanced Due Diligence (EDD) is applied where higher risks are identified.

2. Know Your Customer (KYC) Documentation

Depending on the type of client, the following may be required:

For Individuals

• Valid passport or national ID
• Proof of residential address
• Source of funds / Source of wealth declaration
• Tax identification information
• PEP declaration (if applicable)

For Corporate Entities

• Certificate of incorporation / business registration
• Memorandum & Articles of Association
• Shareholder and UBO (Ultimate Beneficial Owner) register
• Identification of directors and authorized signatories
• Proof of business address
• Corporate structure chart
• Source of funds / Source of wealth documentation
• AML policy and compliance documentation

We may also request additional documents if required by law or risk assessment.

3. Ongoing Monitoring

We conduct continuous monitoring to ensure that client activity remains consistent with:

• The client's profile
• Declared financial behavior
• International regulations
• Sanctions lists and risk indicators

This includes transaction monitoring, periodic reviews, and updated documentation.

4. Sanctions & PEP Screening

All clients and counterparties are screened against:

• Global sanctions lists (e.g., OFAC, EU, UN)
• PEP lists
• Adverse media databases
• Financial crime watchlists

We do not engage in business with individuals or entities:

• Listed on sanctions lists
• Involved in money laundering or terrorist financing
• Operating in high-risk jurisdictions without enhanced vetting
• Attempting to conceal beneficial ownership

5. Reporting Obligations

First Brick Capital Fund complies with all legal obligations to report:

• Suspicious activities
• Unusual transactions
• Attempts to circumvent verification
• Activities involving sanctioned individuals/entities

Reports are filed with relevant authorities as required by law.
We do not inform clients when such reports are submitted (“tipping off” prohibition).

6. Data Protection & Confidentiality

All KYC and AML documentation is handled with strict confidentiality and in accordance with:

• GDPR (General Data Protection Regulation)
• Applicable data protection laws

We retain documentation for the legally required period and use it solely for compliance purposes.

7. Zero-Tolerance Policy

We maintain a zero-tolerance policy towards:

• Money laundering
• Terrorist financing
• Tax evasion
• Fraud
• Bribery and corruption
• Concealment of illicit funds

Any attempt to engage in such activities will result in immediate termination of the business relationship.

8. Client Cooperation

Clients agree to provide accurate, complete, and up-to-date information upon request.
Failure to provide required documentation may result in:

• Delays in onboarding
• Restrictions on activity
• Refusal or termination of service

9. Contact for Compliance Matters

For questions regarding our AML/KYC procedures, or to submit required documentation, please contact:

Compliance Department
First Brick Capital Fund
Email: compliance@firstbrickcapitalfund.org
Website: www.firstbrickcapitalfund.org

10. Updates to This Compliance Statement

We may update this AML/KYC Compliance Statement to reflect new regulations, internal requirements, or risk assessments. Changes will be published on this page.