The Anti-Money Laundering (AML) and Know Your Customer (KYC) policy and procedures of the Company are founded on the legal and regulatory frameworks, particularly the EU AML Directive (Directive (EU) 2015/849). These policies are designed to prevent money laundering, terrorist financing, and other illegal activities. The Company is committed to maintaining high AML/CTF standards, expecting adherence from management and employees. The AML/CTF compliance program includes various measures such as client identification and verification, risk assessments, enhanced due diligence for high-risk clients, monitoring and reporting suspicious activities, client screening against global watchlists, and staff training.
The KYC policy/procedures are integral to these efforts, focusing on client identification and adherence to specific guidelines for client acceptance. Continuous monitoring and information gathering are crucial, especially for high-risk clients. All relevant records and transaction data are maintained electronically for a minimum of ten years.
The Company employs a Risk-Based Approach (RBA) for AML/CTF risk assessments. This includes thorough checks on clients’ identities, backgrounds, source of funds, and transaction patterns, especially for high-risk clients or transactions.
Client identification is mandatory before any financial transaction. This process includes verifying client identity and residence, with no transactions allowed if this information is incomplete or dubious.
Politically Exposed Persons
Special attention is given to Politically Exposed Persons (PEPs), with specific policies and discretionary checks in place. The Company reserves the right to terminate accounts of identified PEPs, with the possibility of an administrative fee.
Clients undergo an automated verification process, submitting personal information and identification documents.
Lastly, the Compliance Officer plays a key role in enforcing AML/KYC policies, overseeing transaction monitoring, policy development, risk assessment, record maintenance, and staff training. The officer is also responsible for liaising with law enforcement authorities as needed.