AML/CTF Statement

1. Who this statement applies to

In this statement, “we”, “us” and “our” mean Andorra Capital Solutions Pty Ltd (ACN 675 464 623 / ABN 32 675 464 623), trading as Private Credit Loans. We are a commercial finance broker arranging property-secured business-purpose loans between Australian corporate borrowers and a panel of non-bank lenders and private investors. We do not provide credit ourselves and we do not hold borrower funds.

2. Our regulatory position

Australia’s anti-money laundering regime is set out in the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (the AML/CTF Act), the AML/CTF Rules, and is administered by AUSTRAC.

The AML/CTF Act applies to entities that provide one or more of the “designated services” in section 6 of the Act. Whether Andorra Capital Solutions Pty Ltd is a reporting entity in respect of any particular transaction depends on the specific designated services performed in connection with that transaction. We assess this on a deal-by-deal basis with reference to the AML/CTF Act, relevant AUSTRAC guidance, and the obligations imposed on us by the panel lenders and private investors we work with (each of whom is independently responsible for its own AML/CTF program).

Independent of our own status, we operate to AML/CTF standards required by our panel lenders and private investors, and we support them in discharging their customer due diligence and ongoing monitoring obligations under their AML/CTF programs.

3. Customer due diligence (KYC)

For every loan we arrange, customer due diligence is conducted before drawdown. This includes:

• Identification and verification of the borrowing entity (company extract, trust deed, partnership agreement, or equivalent).
• Identification and verification of every director and every authorised signatory of the borrowing entity, using primary photographic identification.
• Identification of beneficial owners — natural persons who ultimately own or control 25% or more of the borrowing entity, or who otherwise exercise control by other means.
• For corporate trustees, identification of the trust, the trustee, the appointor (where one exists), and the beneficiaries (in accordance with the AML/CTF Rules applicable to trust customers).
• Source-of-funds enquiry where the loan structure or purpose indicates it is appropriate (deposits, equity contributions, related-party loans).
• Politically Exposed Person (PEP) and sanctions screening of directors, beneficial owners, and the borrowing entity.
• Verification of the genuine business purpose of the funds, consistent with our Business Purpose Declaration requirement.

Enhanced due diligence applies where the customer, the transaction, or the proposed source of funds presents a higher ML/TF risk under the panel lender’s risk framework.

4. Ongoing monitoring

The panel lender or private investor that funds a loan retains the customer relationship for the duration of the loan and conducts ongoing customer due diligence (transaction monitoring, periodic reviews, refreshed identification where appropriate) in accordance with its own AML/CTF program. Where we are notified of a change in beneficial ownership, director, or other material circumstance during the life of a loan we have arranged, we communicate that to the relevant funder.

5. Suspicious matter reporting

If, in the course of arranging or supporting a transaction, we form a suspicion on reasonable grounds that the transaction may be related to money laundering, terrorism financing, tax evasion, or another serious offence, we will:

• Decline to proceed with the transaction or, if already in progress, take steps to halt our further involvement.
• Notify the relevant panel lender or private investor so that it can discharge its own reporting obligations (where it is a reporting entity, the obligation to file a Suspicious Matter Report with AUSTRAC under section 41 of the AML/CTF Act is imposed on it directly).
• Where we are independently the reporting entity in respect of a designated service, file a Suspicious Matter Report directly with AUSTRAC within the timeframes prescribed by section 41.
• Comply with the AML/CTF Act’s “tipping off” prohibition (section 123) — we will not disclose to a customer that a Suspicious Matter Report has been or may be filed.

6. Record keeping

Customer identification records and transaction records are retained for a minimum of seven (7) years from the end of the relationship, consistent with section 107 of the AML/CTF Act and broader record-keeping obligations under the Corporations Act 2001 and the Privacy Act 1988.

7. Training and governance

Personnel involved in customer onboarding and deal assessment receive periodic AML/CTF awareness training. Our director and principal, Nicholas Clunes, has ultimate responsibility for our AML/CTF posture, including ensuring our approach remains current with AUSTRAC guidance and with the requirements of the panel lenders we work with.

8. What this means for borrowers

In practical terms, when you submit a loan enquiry to us, you can expect to be asked for:

• Photographic identification for each director and each authorised signatory of the borrowing entity.
• Confirmation of the beneficial ownership structure of the borrowing entity (and of any trust that is borrowing through a corporate trustee).
• Evidence of the source of the deposit, equity contribution, or other funds you are bringing to the transaction.
• A short written explanation of the business purpose of the loan, supporting the Business Purpose Declaration you will be asked to sign.

We do not skip or shortcut these checks for any deal, regardless of urgency. A genuine business-purpose deal with a clean borrower and clear source of funds typically clears KYC quickly; the checks are designed to identify the small minority of transactions that present risk, not to obstruct legitimate business borrowing.

9. Contact

Questions about this statement can be directed to Nicholas Clunes at nicholas@andorraprivate.com.au or 0480 521 605.