ANTI-MONEY-LAUNDERING (AML) POLICY

Last updated: 26 January 2026

1. Introduction and purpose

KGOGO Arts & Gallery (“KGOGO”, “we”, “us”, or “the Company”) is committed to the highest standards of legal, ethical and financial integrity. This Anti-Money-Laundering Policy (“AML Policy”) sets out the measures we take to prevent our services, events, artworks, experiential products (including NDIRI PANO) and corporate arrangements being used to launder money, finance terrorism or otherwise facilitate financial crime.

2. Scope

This AML Policy applies to:

All KGOGO employees, officers, directors, contractors and agents;

All customers, buyers, visitors, guests, sponsors, donors and other third parties who transact with KGOGO; and

All services, products and business lines operated or marketed by KGOGO.

3. Key definitions

Money laundering (ML): Any process that conceals or disguises the origin of property or proceeds derived from criminal conduct.

Terrorist financing (TF): The provision, collection or use of funds to support terrorist acts or groups.

Customer / Client: Any person or entity that purchases, books, sponsors or otherwise transacts with KGOGO.

PEP: Politically exposed person.

4. Governance and responsibilities

The Company designates a Designated Compliance Officer (DCO) responsible for AML oversight, record keeping, staff training, suspicious activity assessment and reporting. Communications concerning AML matters should be sent to: privacy@kgogo.be.

All staff must promptly report any suspicion of ML/TF to the DCO. Deliberate failure to report or concealment of suspicious conduct is a disciplinary offence.

5. Risk-based customer due diligence (CDD)

KGOGO operates a risk-based approach to CDD, including:

5.1 Identification and verification

For all customers we obtain and verify identity information prior to completing transactions or providing access where practicable. Acceptable identification documents: passport, national ID, driver’s licence, company incorporation documents, proof of address, and evidence of beneficial ownership for legal entities.

For bookings that require access to restricted experiences (e.g., NDIRI PANO), customers must upload identity documentation via our secure verification channel at the time of booking.

5.2 Enhanced due diligence (EDD)

EDD applies to higher-risk profiles, including: PEPs; customers requesting anonymity; complex or opaque ownership structures; transactions involving high values (threshold default: USD 10,000 or equivalent, or where local currency thresholds apply); customers from high-risk jurisdictions; and atypical or suspicious payment routes.

EDD may include additional identity verification, documentary evidence of funds origin, and management approval to proceed.

5.3 Ongoing monitoring

Customer relationships and transactions are monitored for patterns or events indicating unusual or suspicious activity. Changes in behaviour or ownership will prompt additional review.

5.4 Cash and informal channels

Cash transactions above established thresholds are subject to strict verification and may be refused. KGOGO reserves the right to refuse payment methods or channels deemed high-risk.

6. Payment, record keeping and sanctions screening

All payments are processed through reputable payment service providers subject to contractual AML controls.

KGOGO screens customers and transactions against applicable sanctions and watch lists (UN, regional and national lists) and will refuse business with sanctioned individuals or entities.

KGOGO retains CDD records, transaction records and AML case files for no less than seven (7) years after the end of the business relationship or last transaction, or longer where local law demands.

7. Suspicious activity reporting and escalation

Employees must immediately report suspicions to the DCO with full details (identity, transaction description, amounts, basis for suspicion and supporting documents).

The DCO will evaluate reports and, where required by law, file a suspicious transaction report with the relevant Financial Intelligence Unit (FIU) or competent authority and cooperate with law enforcement.

8. Third-party providers

KGOGO requires contractual AML and data protection warranties from payment processors, logistics/shipping partners and other critical vendors. KGOGO conducts due diligence on material third parties.

9. Training and internal controls

KGOGO provides regular AML training to staff, maintains an AML risk assessment, and performs periodic independent testing of AML controls.

10. Cooperation with authorities

KGOGO cooperates with regulatory and law enforcement requests and assists investigations subject to legal obligations.

11. Review

This AML Policy is reviewed at least annually and updated as required by business changes, regulatory developments, or emerging risks.