AML & KYC Policy

Last Updated: October 17, 2025

Coventry Management (“Coventry Management”, “we”, “us”, or “our”) is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance. As part of this commitment, we have implemented robust Anti-Money Laundering (“AML”) and Know Your Client (“KYC”) policies and procedures designed to prevent our services from being used for money laundering, terrorist financing, or other financial crimes.

This policy outlines the principles and practices we follow to comply with applicable laws and regulations in the jurisdictions in which we operate.

1. Regulatory Commitment

Coventry Management complies with all applicable AML and KYC laws, regulations, and guidelines, including those issued by relevant regulatory authorities and international standard-setting bodies.

We actively monitor regulatory developments and continuously update our internal controls to ensure ongoing compliance.

2. Purpose of AML and KYC Measures

Our AML and KYC framework is designed to:

• Verify the identity of our clients
• Understand the nature and purpose of client relationships
• Assess and manage risks associated with financial crime
• Detect and report suspicious activities
• Prevent the misuse of our services for illicit purposes

3. Client Identification (KYC)

Before establishing a client relationship, and on an ongoing basis where required, we conduct identity verification procedures.

Individuals

We may request:

• Full legal name
• Date of birth
• Nationality
• Residential address
• Government-issued identification (e.g., passport or national ID)

Legal Entities

For corporate or institutional clients, we may request:

• Company name and registration details
• Registered office address
• Details of directors and authorized signatories
• Ownership structure and identification of beneficial owners
• Nature of business activities

We may also require certified documentation and independent verification from reliable sources.

4. Risk-Based Approach

Coventry Management applies a risk-based approach to AML and KYC compliance. Clients are assessed and categorized based on risk factors such as:

• Geographic location
• Nature of business or occupation
• Source of funds and wealth
• Transaction patterns
• Politically Exposed Person (“PEP”) status

Enhanced due diligence may be applied to higher-risk clients.

5. Ongoing Monitoring

We conduct ongoing monitoring of client relationships to ensure that transactions are consistent with our understanding of the client’s profile and risk level.

This includes:

• Reviewing transactions for unusual or suspicious activity
• Periodically updating client information
• Reassessing risk classifications

6. Reporting Obligations

Coventry Management complies with all applicable legal obligations to report suspicious activities to relevant authorities.

Where required, we will file reports with appropriate regulatory or law enforcement agencies without notifying the client, in accordance with applicable laws.

7. Record Keeping

We maintain records of client identification, due diligence, and transaction data for the period required by applicable laws and regulations.

These records are securely stored and accessible only to authorized personnel.

8. Data Protection and Confidentiality

All personal and financial information collected as part of our AML and KYC procedures is handled in accordance with applicable data protection laws and our Privacy Policy.

We maintain strict confidentiality and implement appropriate safeguards to protect client information.

9. Training and Internal Controls

Coventry Management maintains internal policies, procedures, and controls designed to ensure compliance with AML and KYC requirements.

Our employees receive regular training on:

• Identifying and preventing financial crime
• Regulatory obligations
• Internal reporting procedures

10. Prohibited Activities

Coventry Management does not accept or maintain relationships with individuals or entities where there is reasonable suspicion of involvement in:

• Money laundering
• Terrorist financing
• Fraud or corruption
• Sanctions violations
• Any other unlawful activities

We reserve the right to decline or terminate relationships that present unacceptable risk.

11. Policy Updates

This AML and KYC Policy may be updated periodically to reflect changes in regulatory requirements or business practices.

Updated versions will be published on this page.

12. Contact Information

If you have any questions regarding this policy or our compliance procedures, please contact:

Coventry Management
Tokyo, Japan
info@coventrymgmt.com