AFCA

If an issue has not been resolved to your satisfaction, you can lodge a complaint with the Australian Financial Complaints Authority, or AFCA. AFCA provides fair and independent financial services complaint resolution that is free to consumers. AFCA is not a government department or agency, and is not a regulator of the financial services industry. AFCA a not-for-profit company, limited by guarantee that is governed by a Board of Directors, which includes equal numbers of industry and consumer representatives.

Website: www.afca.org.au
Email: info@afca.org.au
Telephone: 1800 931 678 (free call) [1]
In writing to: Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001

Anti-Money Laundering and Counter Terrorism Financing Act
Spyre Capital is bound by the Anti-Money Laundering and Counter Terrorism Financing Act and as such will need to verify the identity of any new clients, and their beneficial owners, prior to any service being provided. (Changes to the current legislation may, in the future, impose other due diligence procedures or require the collection of further information from investors). As part of the “know your client” requirements we are also required to understand the source of funds invested. Please see below an explanation of each of these requirements.

What is a beneficial owner?
To comply with AML/CTF Law we require you to disclose beneficial owners. ‘Beneficial owner’ means an individual who ultimately owns or controls, directly or indirectly, the Investor. ‘Control’ includes control as a result of, or by means of, a trust, agreements, arrangements, understandings and practices, whether or not having legal or equitable force and whether or not based on legal or equitable rights, and includes exercising and control through the capacity to determine decisions about financial and operating policies. ‘Owns’ means ownership, either directly or indirectly, of 25% or more of the Investor.

What is a politically exposed person (PEP)?
To comply with AML/CTF Law, we require you to disclose whether you are or have an association with a politically exposed person (PEP). A PEP is an individual who holds a prominent public position or function in a Government body or an international organisation in Australia or overseas, such as a Head of State, or Head of a Country or Government, or a Government Minister, or equivalent senior politician. A PEP can also be an immediate family member of a person referred to above, including spouse, de facto partner, child and a child’s spouse or a parent. A close associate of a PEP, i.e. any individual who is known to have joint beneficial ownership of a legal arrangement or entity is also considered to be a PEP. Where you identify as or have an association with a PEP, we may request additional information from you.

Why do you need to know my source of funds?
As part of our obligations to ‘know our customer’ and to assess money laundering and terrorism financing risk under our AML/CTF program, the AML/CTF Law now requires us to ask about the Investor’s (and of their beneficial owners’) income and assets available for investment and the sources of funds, including their origin. If you have any questions about the new customer identification procedures, please contact our Investor Relations team.