Orange Global Services Inc.

KYC/AML Policy Document

Updated: 31 August 2025

Delaware, USA

Introduction

Orange Global Services Inc., a Delaware C-corporation, is committed to preventing money laundering and the financing of terrorism by adhering to the Bank Secrecy Act (BSA), the Anti-Money Laundering Act (AMLA) of 2020, and all other applicable federal and Delaware state laws and regulations related to anti-money laundering (AML) and countering the financing of terrorism (CFT). This includes compliance with the Corporate Transparency Act (CTA), which mandates the disclosure of beneficial ownership information to the Financial Crimes Enforcement Network (FinCEN).

Objective

Our objective is to establish and maintain a robust KYC/AML framework to ensure that adequate due diligence procedures are consistently applied to all business customers, both at the outset of the relationship and on an ongoing basis. Orange does not onboard or perform KYC on end users. Instead, we verify that our business customers conduct their own KYC in accordance with applicable regulations.

Scope

This policy applies to all employees, business customers, and transactions associated with Orange Global Services Inc. and its wholly owned subsidiaries, such as Orange ZA (Pty) Ltd.

Customer Identification and Verification (KYB)

1. Business Customers Only

Orange exclusively services business clients and performs Know Your Business (KYB) procedures. We do not directly onboard or conduct KYC on end users of those businesses. Our business customers must:

Submit their own KYC/AML policy for review
Certify that they conduct KYC on their end users in accordance with applicable laws