Anti-Money-Laundering and Know-Your-Customer Policy

1. Our obligations

We apply customer due diligence in line with the anti-money-laundering law of To be confirmed: AML jurisdiction. Our nominated officer responsible for money laundering reporting is To be confirmed: MLRO name.

2. Identity verification

Before you can withdraw funds you must complete verification. We collect:

• Your full legal name, date of birth, nationality and residential address.
• A government-issued photographic identity document.
• A recent proof of address, where required.
• A live selfie or liveness check to confirm the document belongs to you.
• Information about the source of the funds you are depositing, where the amount or pattern requires it.

3. Screening

Every applicant is screened against international sanctions lists and checked for politically exposed person status and adverse media. Screening is repeated periodically for the life of the account.

• United Nations Consolidated Sanctions List
• US Treasury OFAC Specially Designated Nationals list
• UK HM Treasury Consolidated List
• EU Consolidated Financial Sanctions List

4. Enhanced due diligence

We apply additional checks where the risk is higher, including where:

• The customer is a politically exposed person, or a close associate of one.
• The customer is connected to a higher-risk jurisdiction.
• The size or pattern of deposits does not match the stated source of funds.
• Funds arrive from an address associated with illicit activity.

5. Ongoing monitoring

Transactions are monitored for patterns that suggest structuring, layering or the use of a third party’s funds. Withdrawals to a destination that is not in your own name are refused.

6. Reporting suspicion

Where we suspect money laundering or terrorist financing we are legally required to report it to To be confirmed: financial intelligence unit. We may be prohibited by law from telling you that a report has been made, and we may have to freeze activity on the account without explaining why. This is not a choice we have.

7. Refusal and closure

We will refuse an application, or close an existing account, where verification cannot be completed, where a sanctions match is confirmed, or where we cannot satisfy ourselves about the source of funds. Where we are permitted to explain, we will.

8. Records and training

Due diligence records and transaction records are retained for To be confirmed: AML retention period after the relationship ends. Staff receive anti-money-laundering training on appointment and at least annually.