Anti-Money Laundering Policy

Last updated: 11 May 2026

1. Purpose

Peachtree Networks is committed to conducting business in compliance with applicable anti-money laundering (AML), counter-terrorist financing (CTF), and economic sanctions laws in every jurisdiction in which we operate. This policy summarises the safeguards we apply across our equipment trading, repair, resale, and recycling activities.

2. Scope

This policy applies to all directors, employees, contractors, agents, and partners acting on behalf of Peachtree Networks or any of its affiliated entities. It governs all customer, vendor, and counterparty relationships, including purchases, sales, consignments, and recycling intake.

3. Customer Due Diligence

Before establishing a commercial relationship, we verify the identity and ownership structure of each counterparty. Required information typically includes registered company name and address, business registration or tax identification number, beneficial ownership details, and the identity of the individuals authorised to transact. Enhanced due diligence is applied to higher-risk counterparties, including those in jurisdictions subject to heightened scrutiny.

4. Sanctions Screening

All counterparties, controlling persons, and shipping endpoints are screened against current sanctions lists, including those maintained by the US Office of Foreign Assets Control (OFAC), the United Nations, the European Union, and the United Kingdom. We do not transact with, supply to, or accept goods from any party that appears on these lists, and we cease activity immediately if a match is identified during an existing engagement.

5. Politically Exposed Persons

Where a counterparty includes politically exposed persons (PEPs) or close associates of PEPs, additional senior-level approval is required before the relationship may proceed, and the relationship is subject to ongoing monitoring.

6. Source of Funds and Goods

We may request documentation of the source of funds for large or unusual transactions and the provenance of equipment offered for purchase. Cash payments are not accepted; all settlements are made through traceable banking channels.

7. Suspicious Activity

Employees are required to escalate any transaction or behaviour that appears inconsistent with a counterparty's stated business or that bears indicators of money laundering, sanctions evasion, or other financial crime. Internal reports are reviewed by the designated compliance contact and, where required, disclosed to the relevant authorities.

8. Record Keeping

Records of due diligence, screening results, transactions, and internal reports are retained for a minimum of five years from the conclusion of the relationship, or longer where required by local law.

9. Training and Governance

All staff with customer- or vendor-facing responsibilities receive AML and sanctions awareness training during onboarding and at regular intervals thereafter. The policy is reviewed annually and updated as regulations or business circumstances change.

10. Contact

Questions about this policy, or about a specific compliance matter, may be directed to:

Email: compliance@ptnw.com