Anti-Money Laundering Policy

Purpose

CYKA Petroleum Limited is committed to the highest standards of Anti-Money Laundering compliance and requires all personnel to adhere to these standards to prevent use of our products and services for money laundering purposes. We will continue to examine our Anti-Money Laundering strategies, goals and objectives on a regular basis and maintain an effective Anti-Money Laundering programme for all our transactions that reflects best global practice.

Definitions

Money laundering is the participation in any transaction that seeks to conceal or disguise the nature or origin of funds derived from illegal activities such as, fraud, corruption, organized crime, or terrorism etc. It involves the introduction of illegally obtained monies or other valuables into the financial or non-financial institutions, separation of the proceeds of criminal activity from their source through the use of layers of complex financial transactions designed to hamper an audit trail and disguise the origin of the funds and provide anonymity and placing the laundered proceeds back into the economy as legitimate funds.

Scope

This Policy applies to all employees and aims to maintain the high standards of conduct which currently exists within the Company by preventing criminal activity through money laundering. The Policy sets out the procedures which must be followed to enable the Company to comply with its legal obligations. Failure by a member of staff to comply with the procedures set out in this Policy may lead to disciplinary action being taken against them.

Responsibilities

All our employees are required to comply with the following procedures and principles:

• Establish the proper identity of our customer, who owns or controls the customer or its assets or on whose behalf the transaction is carried out when entering into any lasting business relationship or when performing a single transaction or deal

• Establish the purpose of business relationship to ensure it is in line with the business objectives of the company

• All suspicious circumstances/transactions must be reported to the competent authorities according to the local law

• No payment will be accepted in cash
• Records must be kept of all financial transactions and data obtained for the purpose of identification and audit trail, as well as of all documents related to money laundering topics (e.g. files on suspicious activity reports)

• Where it is suspected that money laundering activity is taking/has taken place or an employee becomes concerned that their involvement in a matter may amount to a prohibited act under the law, this must be disclosed as soon as practicable to the management. The disclosure should be within “hours” of the information coming to the employee’s attention, not weeks or months later. SHOULD THIS NOT BE DONE, THEN THE EMPLOYEE MAY BE LIABLE TO PROSECUTION