## the Wolfsberg Group

**Financial Institution Name:**  
**Location (Country) :**

| Benefit Street Partners Limited |  
| --- |  
| United Kingdom |

| No # Question | Answer |  
| --- | --- |  
| 1. ENTITY & OWNERSHIP |  |  
| 1 | Full Legal name | Benefit Street Partners Limited |  
| 2 | Append a list of foreign branches which are covered by this questionnaire (if applicable) | N/A |  
| 3 | Full Legal (Registered) Address | Cannon Place 78 Cannon Place London EC4N 6HL |  
| 4 | Full Primary Business Address (if different from above) | As above |  
| 5 | Date of Entity incorporation/establishment | 12 August 1994 |  
| 6 | Select type of ownership and append an ownership chart if available |  |  
| 6 a | Publicly Traded (25% of shares publicly traded) | No |  
| 6 a1 | If Y, indicate the exchange traded on and ticker symbol | N/A |  
| 6 b | Member Owned/Mutual | No |  
| 6 c | Government or State Owned by 25% or more | No |  
| 6 d | Privately Owned | Yes |  
| 6 d1 | If Y, provide details of shareholders or ultimate beneficial owners with a holding of 10% or more | Alcentra Limited is a wholly owned subsidiary of Franklin Resources Inc., the holding company for the various subsidiaries that form the global Investment management organization known as Franklin Templeton. |  
| 7 | % of the Entity's total shares composed of bearer | 0% |  
| 8 | Does the Entity, or any of its branches, operate under an Offshore Banking License (OBL)? | No |  
| 9 | Does the Bank have a Virtual Bank License or provide services only through online channels? | No |  
| 10 | Provide Legal Entity Identifier (LEI) if available | N/A |  
| 2. AML, CTF & SANCTIONS PROGRAMME |  |  
| 11 | Does the Entity have a programme that sets minimum AML, CTF and Sanctions standards regarding the following components: |  |  
| 11 a | Appointed Officer with sufficient experience/expertise | Yes |  
| 11 b | Adverse Information Screening | Yes |  
| 11 c | Beneficial Ownership | Yes |  
| 11 d | Cash Reporting | Not Applicable |  
| 11 e | CDD | Yes |  
| 11 f | EDD | Yes |  
| 11 g | Independent Testing | Yes |  
| 11 h | Periodic Review | Yes |  
| 11 i | Policies and Procedures | Yes |  
| 11 j | PEP Screening | Yes |  
| 11 k | Risk Assessment | Yes |  
| 11 l | Sanctions | Yes |  
| 11 m | Suspicious Activity Reporting | Yes |  
| 11 n | Training and Education | Yes |  
| 11 o | Transaction Monitoring | Yes |  
| 12 | Is the Entity's AML, CTF & Sanctions policy approved at least annually by the Board or equivalent Senior Management Committee? | Yes |  
| 13 a | Components of its AML, CTF & Sanctions programme? If Y, provide further details | No N/A |  
| 14 | Does the entity have a whistleblower policy? | Yes |  
| 3. ANTI BRIBERY & CORRUPTION |  |  
| 16 | Consistent with applicable ABC regulations and requirements to reasonably prevent, detect and report bribery and corruption? | Yes |  
| 17 | Does the Entity provide mandatory ABC training to: |  |  
| 17 a | Board and Senior Committee Management | Yes |  
| 17 b | 1st Line of Defence | Yes |  
| 17 c | 2nd Line of Defence | Yes |  
| 17 d | 3rd Line of Defence | Yes |  
| 17 e | Third parties to which specific compliance activities | Yes |  
| 17 f | Non-employed workers as appropriate (contractors/consultants) | Yes |  
| 4. AML, CTF & SANCTIONS POLICIES & PROCEDURES |  |  
| 18 | Has the Entity documented policies and procedures consistent with applicable AML, CTF & Sanctions regulations and requirements to reasonably prevent, detect and report: |  |  
| 18 a | Money laundering | Yes |  
| 18 b | Terrorist financing | Yes |  
| 18 c | Sanctions violations | Yes |  
| 19 | Does the Entity have policies and procedures that: |  |  
| 19 a | Prohibit the opening and keeping of anonymous and fictitious named accounts | Yes |  
| 19 b | Prohibit the opening and keeping of accounts for unlicensed banks and/or NBFIs | Yes |  
| 19 c | Prohibit dealing with other entities that provide banking services to unlicensed banks | Yes |  
| 19 d | Prohibit accounts/relationships with shell banks | Yes |  
| 19 e | Prohibit dealing with another Entity that provides services to shell banks | Yes |  
| 19 f | Prohibit opening and keeping of accounts for Section 311 designated entities | Yes |  
| 19 g | Prohibit opening and keeping of accounts for any unlicensed/unregulated remittance agents or money transfer agents | Yes |  
| 19 h | Assess the risks of relationships with domestic and foreign PEPs | Yes |  
| 19 i | Define the process for escalating financial crime risk issues/potentially suspicious activity identified by employees | Yes |  
| 19 j | Outline the processes regarding screening for sanctions, PEPs and Adverse Media/Negative News | Yes |  
| 20 | Has the Entity defined a risk tolerance statement that defines a risk boundary around their business? | Yes |  
| 21 | Does the Entity have record retention procedures that comply with applicable laws? | Yes |  
| 21 a | If Y, what is the retention period? | 5 years or more |  
| 5. KYC, CDD and EDD |  |  
| 22 | Does the Entity verify the identity of the customer? | Yes |  
| 23 | Do the Entity's policies and procedures set out when CDD must be completed? | Yes |  
| 24 a | Customer identification | Yes |  
| 24 b | Expected activity | Yes |  
| 24 c | Nature of business/employment | Yes |  
| 24 d | Ownership structure | Yes |  
| 24 e | Product usage | Yes |  
| 24 f | Purpose and nature of relationship | Yes |  
| 24 g | Source of funds | Yes |  
| 24 h | Source of wealth | Yes |  
| 25 | Are each of the following identified: |  |  
| 25 a | Ultimate beneficial ownership | Yes |  
| 25 b | Authorised signatories (where applicable) | Yes |  
| 25 c | Key controllers | Yes |  
| 25 d | Other relevant parties | Yes |  
| 27 | Does the due diligence process result in customers receiving a risk classification? | Yes |  
| 28 | Does the Entity have policies, procedures and processes to review and escalate potential matches? | Yes |  
| 29 | Is KYC renewed at defined frequencies based on risk rating? | Yes |  
| 29 a | If yes, select all that apply: |  |  
| 29 a1 | Less than one year | No |  
| 29 a2 | 1 – 2 years | Yes |  
| 29 a3 | 3 – 4 years | Yes |  
| 29 a4 | 5 years or more | Yes |  
| 29 a5 | Trigger-based or perpetual monitoring reviews | Yes |  
| 30 | From the list below, which categories of customers or industries are subject to EDD or restricted? |  |  
| 30 a | Arms, Defence, Military | Do not have this category of customer or industry |  
| 30 b | Respondent Banks | Do not have this category of customer or industry |  
| 30 c | Embassies/Consulates | Do not have this category of customer or industry |  
| 30 d | Extractive industries | Do not have this category of customer or industry |  
| 30 e | Gambling customers | Do not have this category of customer or industry |  
| 30 f | General Trading Companies | Do not have this category of customer or industry |  
| 30 g | Marijuana-related Entities | Do not have this category of customer or industry |  
| 30 h | MSB/MVTS customers | Prohibited |  
| 30 i | Non-account customers | Do not have this category of customer or industry |  
| 30 j | Non-Government Organisations | EDD on risk-based approach |  
| 30 n | PEPs | EDD on risk-based approach |  
| 30 o | PEP Close Associates | EDD on risk-based approach |  
| 30 p | PEP Related | EDD on risk-based approach |  
| 30 t | Shell banks | Prohibited |  
| 6. MONITORING & REPORTING |  |  
| 33 | Does the Entity have risk based policies, procedures and monitoring processes for the identification and reporting of suspicious activity? | Yes |  
| 34 | Does the Entity have regulatory requirements to report suspicious transactions? | Yes |  
| 34 a | If Y, does the Entity have policies, procedures and processes to comply with suspicious transactions reporting requirements? | Yes |  
| 35 | Does the Entity have policies, procedures and processes to review and escalate matters arising from the monitoring of customer transactions and activity? | Yes |  
| 7. PAYMENT TRANSPARENCY |  |  
| 36 | Does the Entity adhere to the Wolfsberg Group? | Yes |  
| 37 a | Does the Entity have policies, procedures and processes to comply with and have controls in place to ensure compliance? | Yes |  
| 38 | Does the Entity have a Sanctions Policy approved by management regarding compliance with sanctions law? | Yes |  
| 39 | Does the Entity have policies, procedures or other controls reasonably designed to prohibit and/or detect actions taken to evade applicable sanctions prohibitions? | Yes |  
| 40 | Does the Entity screen its customers against Sanctions Lists? | Yes |  
| 41 a | Consolidated United Nations Security Council Sanctions List (UN) | Used for screening customers and beneficial owners |  
| 41 b | United States Department of the Treasury's Office of Foreign Assets Control (OFAC) | Used for screening customers and beneficial owners |  
| 41 c | Office of Financial Sanctions Implementation HMT (OFSI) | Used for screening customers and beneficial owners |  
| 41 d | European Union Consolidated List (EU) | Used for screening customers and beneficial owners |  
| 41 e | Lists maintained by other G7 member countries | Used for screening customers and beneficial owners |  
| 41 f | Other (specify) | Various local and geolocation sanction lists |  
| 42 | Does the Entity have a physical presence in countries/regions against which sanctions have been enacted? | No |  
| 9. TRAINING & EDUCATION |  |  
| 43 | Does the Entity provide mandatory training? | Yes |  
| 43 a | Includes identification and reporting of transactions to government authorities | Yes |  
| 43 b | Examples of different forms of money laundering and terrorist financing | Yes |  
| 43 c | Internal policies for controlling money laundering | Yes |  
| 43 d | New issues occurring in the market | Yes |  
| 44 | Is the above mandatory training provided to: |  |  
| 44 a | Board and Senior Committee Management | Yes |  
| 44 b | 1st Line of Defence | Yes |  
| 44 c | 2nd Line of Defence | Yes |  
| 44 d | 3rd Line of Defence | Yes |  
| 44 f | Non-employed workers (contractors/consultants) | Yes |  
| 10. AUDIT |  |  
| 45 | Does the Entity have an internal audit function or other independent third party that assesses FCC AML, CTF, ABC, Fraud and Sanctions policies and practices on a regular basis? | Yes |  
| Signature Page | Wolfsberg Group Financial Crime Compliance Questionnaire 2023 (FCCQ V1.2)

Benefit Street Partners Limited _______________________________________________________________________________ (Financial Institution name)  
Ben Woodley (MLRO and Head of Compliance)  
I certify that the answers provided in this Wolfsberg FCCQ are complete and correct to my honest belief.  
4/30/2026 6:37 AM PDT  
______________________________________________ (Signature & Date)

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