Due Diligence Form A

COMPANY NAME AND ADDRESS
Mirabello Consultancy DMCC, Office 412, Goldcrest Executive, Cluster C, Jumeirah Lake Towers JLT, Dubai, United Arab Emirates
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CLIENT (CONTRACTING PARTY)

In order for us to conduct proper due diligence on you, we require certain personal information from you. You are kindly requested to enclose a copy of your passport with this Internal Due Diligence, duly completed, dated and signed.

Surname:
Surname
First name(s):
Surname
Other name(s) you are known by:
Other Name
Nationality
Nationality
Place of birth/date of birth:
Place of birth/date of birth
/
Permanent residential address:
Permanent address
Email address:
tigran@tcf.team
Occupation/business activities:
occupation
Business name and address:
Bisness name and address
/
Purpose of seeking alternative citizenship / residence:
purpose
Program of interest:
program of interest
Are you aPolitically Exposed Person (“PEP”)?
YES
NO

While there is no global definition of a PEP, the Financial Action Task Force has issued guidelines (www.fatf-gafi.org), which generally refer to the following: A PEP isa current or former (during the past ten years) senior official in the executive, legislative, administrative, military, or judicial branch of the state (elected or not), a senior official of a major political party, a senior executive of a government owned commercial enterprise, and/or being a corporation, business or other entity formed by or for the benefit of any such individual; an immediate family member of such individual, meaning spouse, parents, siblings, children, and spouse’s parents or siblings, or any individual publicly known (or actually known by the relevant financial institution) to be a close personal or professional associate. If you are in doubt whether you qualify as PEP or not, please tick Yes above.

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FAMILY MEMBERS

In order for us to proceed with the due diligence process, we also require personal information about any family member who may be included in your Personal Application. You are kindly requested to enclose a copy of the passports of such family members within this process.. Full name(s) of family members / relationship to Client:

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BANKING REFERENCE

Please note that funds must generally be remitted from your personal bank account. In the exceptional event that Mirabello agrees to accept funds from a third party on your behalf, then the relevant account from which funds are actually transferred must be named below, and additional due diligence information and documentation will be required from that third party . Funds will in any case only be accepted by Mirabello if this Internal Due Diligence is duly completed, executed and passport copies are enclosed. Funds will be wired to Mirabello from the following bank account:

Account in name of (should be in your personal name):

account in name

Account Number or IBAN and SWIFT code:

iban swift

Bank name and full address:

bank name

Due Diligence Form A

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BENEFICIAL OWNER DECLARATION I the undersigned herewith declare:

that I am the ultimate beneficial owner of all funds remitted to Mirabello. Please continue to clause 5.
that the ultimate beneficial owner(s) of all funds remitted to Mirabello is (are):
Surname:
Beneficial Surname
First name(s):
Beneficial first name
Other name(s) you are known by:
Beneficial other name
Nationality
Beneficial Nationality
Place of birth
Beneficial date of birth
Date of birth:
Beneficial date of birth
Permanent residential address:
Beneficial resident address
Business name and address:
Beneficial name and address
What is the connection between you and the beneficial owner of the funds?
Beneficial comment
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Acknowledgment, Authorization & Consent

I acknowledge and agree that completion and submission of this Internal Due Diligence with applicable documentation authorizes and directs Mirabello to enquire and conduct due diligence and background verification checks on the persons named here in. I here by authorize Mirabello for the procurement of a Background Verification Report from a third-party service provider. In that regard, I consent for Mirabello to disclose the personal data, including this Internal Due Diligence and the provided passport copies, and the nature of my relationship with Mirabello, to such third-party service provider to be able to request such a report. I understand and consent to the use and processing of such personal information by the third-party provider in the ordinary and normal course of its business and function. I here by confirm that I am fully authorized by all family members named herein to provide Mirabello with their personal data and their passport copies for the purposes set out in this Internal Due Diligence.

I here by give consent to Mirabello processing the Sensitive Data required by or provided to Mirabello.
I here by confirm that I am fully authorized by all persons named here in to give such consent on their behalf to Mirabello processing their Sensitive Data. I agree to provide Mirabello with a written confirmation of such person’s consent upon Mirabello’s request.

Due Diligence Form A

DATA PROTECTION NOTICE

The purpose of this Data Protection Notice (“Notice”) is to set out the basis on which any personal data is processed by us and make you aware of how we will handle your personal data, our obligations in regard to processing your personal data responsibly as well as your data protection rights. We process your data in an appropriate and lawful manner, in accordance with the applicable laws and regulations to which Mirabello is subject, including without limitation the General Data Protection Regulation (Regulation (EU) 2016/679, herein “GDPR”) which is in force as of 25 May 2018. For the purposes of these data protection laws, Mirabello is the data controller (as defined in the GDPR). We have appointed a Data Protection Officer (the “DPO”) who can be contacted via the following address: data@mirabelloconsultancy.com. You can address any comments, queries or complaints to this address.
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INFORMATION WE PROCESS

1.1. Information you provide in this Form A The personal data which you shall be requested to provide in this Form A is categorized into personal details and remittance information: a) Personal Details These include your name, surname, other names you are known by, nationality, place of birth, date of birth, permanent residential address, email address, occupation/business activities, business name and address as well as the information whether you are a politically exposed person (the designation of which may become applicable to you by reason of your familial relationship with another person). You will also be requested to provide a copy of your passport, and, where applicable, a copy of the passport of your family member(s) that will be included in your personal application for residence or citizenship. As also explained in the Form A below, should any funds be remitted by a third party to us on your behalf, you are also required to fill in the name of such third party and in addition submit one more Due Diligence Form A, duly completed, dated and signed by the third party and to provide a passport copy of such third party remitter. Should a third party be the ultimate beneficial owner of such funds, you are required to fill in the name, surname, other names, nationality, place of birth, date of birth, permanent residential address, email address, occupation/business activities, business name and address as well as the information about your relationship to the ultimate beneficial owner and provide a passport copy of this person. b) Remittance Information These include banking details, including name of the account holder, account number and IBAN No./SWIFT code, the name and location of the bank. 1.2. Information we receive from other source: We obtain further personal data about you from other sources to conduct further and/or enhanced due diligence including publicly available sources as well as compliance databases and compliance and due diligence service providers

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LEGAL BASIS OF PROCESSING

We process your information on the basis of the performance of any contract with you, of legitimate interests as stated further below and, where applicable, in order to comply with any legal obligations in the jurisdictions that we operate in. We may also process your information in order to defend us against legal claims or in order to comply with an order of any court, tribunal or authority. Mirabello offers its services only with respect to specific Residence- and/or Citizenship-by- Investment Programs. Mirabello only accepts clients as applicants and will only submit the personal application of clients, and, where applicable, any family member(s), subject to a satisfactory outcome of a due diligence undertaken by Mirabello and/or a third-party company. We therefore use the information you provide us within this Form A to conduct due diligence and apply Know Your Customer (“KYC”) procedures on you, and, where applicable, any family member, third party remitter and ultimate beneficial owner. We also combine the information you provide to us with information we receive from other sources. Based on the outcome of such due diligence, we decide whether we may enter into a contract for services with you and whether we may accept any funds from you and/or the third-party remitter. It is in the utmost interest of Mirabello Consultancy Ltd. as well as other stakeholders in the field of investment migration and Residence- and/or Citizenship-by-Investment, such as professional associations, governments and international organizations to prevent the abuse of Residence- and/or Citizenship-by-Investment Programs. By applying relevant and proper due diligence procedures we are effectively reducing the risk of engaging with individuals who wish to obtain passports for the purpose of any illicit financial activity, money laundering, evading sanctions or other crimes. By processing your, and where applicable your family member’s, third party remitter’s and the ultimate beneficial owner’s personal data we make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you, and where applicable your family member(s), third party remitter(s) or ultimate beneficial owner(s), unless we have your consent or are otherwise required or permitted to by law. You can always obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Generally, we do not rely on consent as a legal basis for processing your information. However, in this Form A you are also requested to provide your and/or your family member’s, third party remitter’s or ultimate beneficial owner’s consent for certain purposes of processing. Please note that if you do not provide the required consent, we may be unable to process your application for business and to provide the services which you request.

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DISCLOSURE OF YOUR PERSONAL DETAILS

In order for us to conduct proper due diligence and apply KYC procedure we need to share your personal data provided with this Form A and/or by other sources with third parties for control, reporting and storage purposes. All involved parties we work together with, apply the security measures and safeguards as described below. We may also share the personal data provided in this Form A and by other sources with the government authorities in the country where you seek to obtain residence or citizenship. This transfer is naturally necessary in order to obtain the approval for the grant of residence or citizenship following an application to that effect. However, we shall only disclose the information which is necessary for the purposes of our legitimate interests and in order to comply with our legal obligations. In order to be able to process payment of the funds you transmit to us we may have to share your personal details with the banking institution handling the transaction. As the case may be, we may also share your personal data with service suppliers such as local authorized agents who submit your personal application on your behalf to the government authorities in the countries where you seek to obtain residence or citizenship as well as service providers (in their capacity as data processors) who are necessary for us to conduct appropriate due diligence on you and where applicable your family member(s), third party remitter(s) and ultimate beneficial owner(s), such as compliance and due diligence service providers. These processors store and process your data on the basis of strict confidentiality and subject to the appropriate security measures and safeguards as described below. Where such service providers process your personal data in their own right (in their capacity as data controllers) we may provide you with their data privacy notice relating to your personal data. We may also disclose personal data if we are under a duty to disclose or share your personal data to comply with any legal obligations, judgment or under an order from a court, tribunal or authority. We may also disclose the personal data to protect our rights, property or safety or defend us against legal claims.

Due Diligence Form A

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THIRD PARTY ACCESS TO YOUR PERSONAL DATA

Personnel or other members of Mirabello may access your personal data for the reasons as set out above. We work closely with third parties in order to provide you the services you request. These third parties may have access to your personal data. Such third parties include cloud storage providers and IT service providers.
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TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

Where we share your personal data with internal or external third parties as set out above, this may involve transferring your personal data outside the jurisdictionwhere Mirabello is established and outside the European Economic Area. We will transfer your personal data in accordance with standard contractual clauses(European Commission: Model contracts for the transfer of personal data to third countries) to ensure your personal data is transferred securely and in compliancewith data protection legislation, including the GDPR.
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DATA SECURITY / DATA STORAGE / DATA MINIMISATION

We will ensure that appropriate security measures are taken against unlawful or unauthorized processing of personal data, and against accidental loss of, ordamage to, personal data. Such measures shall include (a) encrypting the personal data we process, (b) ensuring the ongoing confidentiality, integrity, availabilityand resilience of the processing systems and services that we use; (c) ensuring that the availability of and access to personal data can be restored in a timelymanner after an accident; (d) regularly assessing and evaluating the effectiveness of the technical and organizational measures adopted; and (e) carrying out a dataprotection impact assessment prior to implementing a new set of processing operations. All personal data is stored in a secure environment and we have physicaland electronical data access controls in place whereby access is granted only to persons authorized to access the data on a need to know basis, all of whom arebound by confidentiality obligations not to disclose any personal data. We have data integrity controls in place. Please contact us ondata@mirabelloconsultancy.com for further details with respect to our technical and organizational security measures. No method of transmission of data is onehundred percent (100%) secure and absolute security cannot be guaranteed. We shall only store your data as long as this is strictly necessary for the purposes forwhich it was collected. Retention of most data shall not exceed 10 years from the date of termination or completion of our services (in case we did not enter into acontract from the date of the data collection). This period of retention enables us to use the data for the defense of any potential legal claims (taking into accountthe applicable limitation periods prescribed at law) as well as to comply with our legal obligations such as applicable accounting and tax laws. Whenever and to theextent possible, we anonymize the data we hold about you when it is no longer necessary to identify you from the personal data which we hold about you.
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YOUR RIGHTS AS A DATA SUBJECT

You are entitled to exercise the following rights:
7.1. Right to Access Information: You have the right to request information as to whether or not your personal data is being processed by us as well asinformation as to how and why it is processed. You may send an email to data@mirabelloconsultancy.com requesting information as to the personal data which weprocess. You shall receive one copy free of charge via email of the personal data which is undergoing processing. We may charge a reasonable fee, if your request isclearly unfounded, repetitive or excessive in which case we may also refuse to comply with your request in these circumstances.
7.2. Right to object: You may ask us not to process your personal data for marketing purposes and your data will no longer be processed for such purposes.
7.3. Right to withdraw consent: You have the right to withdraw your consent to this Notice, and the processing practices described herein, at any time by sendingan email to data@mirabelloconslutancy.com. This will not however affect the lawfulness of processing which we carried out on the basis of such consent before itswithdrawal. Withdrawal of consent may affect or impact the possibility of us providing you with the services.
7.4. Right to rectification:  You have the right to obtain rectification of any inaccurate personal data about you that we have processed, update any data which isout-of-date and the right to have incomplete personal data completed, including by means of a supplementary statement.
7.5. Right to erasure: You have the right to obtain the erasure of personal data we have concerning you when your personal data is no longer required where:You withdraw your consent to us processing your personal data;Your personal data no longer needs to be processed; orYour personal data has been unlawfully processed.
7.6. Right to Restriction of Processing: You have the right to restrict our processing activities where:
• You contest the accuracy of this personal data, for a periodenabling us to verify the accuracy of the same personal data;
• Our processing is deemed unlawful, and you oppose the erasure of your personal data and requestrestriction of its use instead;
• We no longer need your personal data for the purposes stated in this Notice, but you require it for the establishment, exercise ordefense of legal claims; or you have objected to our processing pending the verification whether the legitimate grounds of our processing activities overrode thosepertaining to you.
7.7. Right of Data Portability: As from 25 May 2018, you shall have the right to receive your personal data in a structured and machine-readable format andtransmit this data to another controller.
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COMPLAINTS

We welcome any comments, complaints and queries in relation to data protection. As indicated above you may contact us at data@mirabelloconsultancy.com andwe shall try our best to deal with any issue or concern you may have. If we fail to address your concerns, you have the right to lodge a complaint with the dataprotection authority in the jurisdiction where you or Mirabello is based and where Mirabello is based and/or represented outside the European Economic Area withthe Swiss Federal Data Protection and Information Commissioner (FDPIC) at www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html, as the relevant nationalsupervisory authority on data protection matters for us.
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DECLARATION

I hereby confirmthatthe information provided in this Internal Due Diligence, iscorrect,completeand notmisleading in any way. I hereby acknowledgemy obligation to informMirabello immediately of any changestothe information I have provided and know that if I intentionally provide wrong or incorrect information or falsify thisFormAthismay be prosecuted asacriminal offence underapplicable laws. I agreethat in case I intentionally provide wrong or incorrect information or falsify this Internal Due Diligence, I willindemnify Mirabelloagainstall losses, liabilities,actions, proceedings,claims,costsand expenses incurred orthreatened against Mirabellocaused by my actions.

Date

current date

Signature

Addition: Please provide a Passport copy (Data and Signature Page) of all applying family members.