Effective Date: 01/01/2026

Purpose

The purpose of this Anti-Money Laundering (AML) Policy is to establish procedures and guidelines for Octopus Financial Group LLC to comply with all applicable AML laws and regulations. This policy aims to prevent, detect, and report any activities related to money laundering, terrorist financing, or other illegal financial activities in connection with our mortgage broker services.

Scope

This AML Policy applies to all employees, officers, directors, and agents of Octopus Financial Group LLC. It covers all business activities conducted by the company, including client onboarding, loan processing, and financial transactions.

Regulatory Framework

Octopus Financial Group LLC is committed to complying with the following U.S. laws and regulations related to AML:

• The Bank Secrecy Act (BSA)

• The USA PATRIOT Act

• Financial Crimes Enforcement Network (FinCEN) regulations

• Office of Foreign Assets Control (OFAC) requirements

Client Due Diligence (CDD)

Octopus Financial Group LLC shall implement a risk-based approach to client onboarding and due diligence. The following steps must be followed:

1. Identification and Verification: Collect and verify the identity of all clients using government-issued identification.

2. Know Your Customer (KYC): Obtain relevant information about the client’s financial background, purpose of the loan, and intended use of funds.

3. Ongoing Monitoring: Continuously monitor client activities to identify any unusual or suspicious behavior.

Suspicious Activity Reporting (SAR)

Employees must report any suspicious activities to the AML Compliance Officer. The AML Officer will determine if a Suspicious Activity Report (SAR) must be filed with FinCEN. Examples of suspicious activities include:

• Structuring transactions to avoid reporting requirements.

• Providing false or misleading information.

• Transactions involving high-risk jurisdictions.

Recordkeeping

Octopus Financial Group LLC shall maintain all records related to AML compliance for a minimum of five years. These records include:

• Client identification documents.

• Transaction records.

• Suspicious Activity Reports (SARs).

• Training records.

Employee Training

All employees must undergo regular AML training to understand their obligations under this policy. Training shall cover:

• AML laws and regulations.

• Identifying and reporting suspicious activities.

• Proper client due diligence procedures.

Risk Assessment

Octopus Financial Group LLC shall conduct regular risk assessments to identify and mitigate money laundering risks. The risk assessment will evaluate:

• Client types and risk profiles.

• Geographic risks.

• Product and service risks.

Internal Controls

Octopus Financial Group LLC will implement internal controls to ensure compliance with this policy. These controls include:

• Segregation of duties.

• Regular audits and reviews.

• Secure data handling practices.

Penalties for Non-Compliance

Non-compliance with this AML Policy may result in disciplinary action, including termination of employment. Additionally, regulatory authorities may impose civil and criminal penalties for AML violations.

Policy Review and Updates

This AML Policy shall be reviewed annually by the AML Compliance Officer to ensure it remains effective and compliant with current regulations. Updates to the policy will be communicated to all employees.

Approval

This AML Policy is approved by the management of Octopus Financial Group LLC and is effective as of the date indicated above.