Anti-Money Laundering and Compliance Policy

Prosperous Living Investment (“PLI”, “we”) is a consultancy firm specialising in residency by investment, citizenship by investment, international real estate, and asset structuring for high-net-worth individuals. We are committed to applying high standards in Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) to protect our clients, partners, and our reputation against financial crime risks.

1. Purpose and scope

This policy establishes the principles and measures that PLI applies to identify clients, assess risks, verify the source of funds, and prevent our services from being used for money laundering, terrorist financing, or sanctions evasion. This policy applies to all partners, board members, staff, and associates of PLI, as well as all advisory services we provide.

2. Legal framework

PLI's operations are guided by the following standards and regulations, to the extent applicable to each transaction:

• Anti-Money Laundering Law No. 14/2022/QH15 and relevant Vietnamese implementing regulations;
• Recommendations of the Financial Action Task Force (FATF);
• Directive (EU) 2015/849 on the prevention of money laundering, for programmes related to the European Union;
• Sanctions regimes of the United Nations, the European Union, the United Kingdom, and the United States (OFAC).

3. Customer identification and due diligence (KYC/CDD)

Before engagement and throughout the service provision process, PLI performs customer identification and profile assessment, including:

• Collecting and verifying customer identity via identification documents, passports, and valid documentation;
• Identifying the ultimate beneficial owner for corporate clients;
• Understanding the purpose and nature of the relationship, as well as the customer's expected transaction profile.

4. Verification of source of funds and source of wealth

PLI requires customers to provide documentation proving the legal source of funds and wealth for the investment. We reserve the right to request additional information and will not support transactions where the origin of assets cannot be satisfactorily proven.

5. Sanctions and Politically Exposed Persons (PEP) screening

We cross-reference customers and related parties against sanctions lists from the United Nations, EU, UK, and United States (OFAC), and identify Politically Exposed Persons (PEP). For high-risk cases, PLI applies Enhanced Due Diligence (EDD) before proceeding.

6. Risk-based approach

PLI applies a risk-based approach: the level of due diligence is adjusted according to the risk profile of each customer, country, programme, and transaction structure. Factors such as high-risk countries, complex ownership structures, or unusual transactions will increase the level of scrutiny.

7. Refusal of transactions and reporting of suspicious transactions

PLI reserves the right to refuse engagement or terminate relationships with customers who do not meet due diligence requirements or when suspicious signs are detected. We cooperate with competent authorities and perform reporting in accordance with applicable laws.

8. Record keeping

Customer identification records, documentation proving the source of funds, and transaction information are stored securely and confidentially for the period required by law, and are processed in accordance with personal data protection regulations.

9. Training and personnel responsibility

PLI personnel are trained and kept aware of anti-money laundering practices relevant to their roles, ensuring the timely identification and handling of risk indicators during the consultation process.

10. Compliance contact point

For any queries regarding this policy or compliance matters, please contact:[email protected].

11. Review and updates

This policy is reviewed periodically and updated when there are changes in legal regulations or operational practices. The latest updated version is published on this page.