Dated: August 27, 2025
Version: 1.2
Updated: Annually
Akili Ventures (referred to in this policy as “Akili” or the “Company”) is committed to conducting business with integrity and in compliance with all applicable laws. This commitment is embodied in Akili’s Code of Conduct policies.
The purpose of this Anti-Money Laundering and Counter-Terrorist Financing Policy (“Policy”) is to support Akili’s compliance with global AML and CTF requirements, including obligations under U.S. law, the Financial Action Task Force (FATF) recommendations, and other applicable international standards.
Money laundering and terrorist financing are risks in large-scale financial transactions, including those involving Akili’s investments, partners, and clients. Akili strictly prohibits any employee, partner, officer, or director from permitting the Company’s services or operations to be used for such purposes. Violations can result in severe civil and criminal penalties for both the Company and individuals involved.
Accordingly, Akili requires that “Know Your Customer” (“KYC”) and related due diligence procedures be applied whenever appropriate.
This Policy applies to all employees, partners, officers, and directors of Akili (“Akili Representatives”).
Akili Representatives must ensure that any third party engaged to conclude transactions on Akili’s behalf complies with this Policy.
Prior to executing a binding agreement or term sheet for:
…the Akili Representative responsible must refer the counterparty (“Customer”) to Akili’s compliance manager (“Reviewer”) for completion of KYC procedures.
The Reviewer will determine the appropriate level of KYC based on risk.