AML/CFT Policy

• Commitment: Formally state the firm’s commitment to prohibiting money laundering and terrorist financing.
• Legal Basis: Cite compliance with Regulation (EU) 2024/1624 (AMLR) and relevant national transpositions of AMLD6. 

• Compliance Manager: Appointment of a senior management member responsible for implementing the AML/CFT framework.
• Compliance Officer: Designation of a senior individual for daily operations, including reporting to Financial Intelligence Units (FIUs).
• Independent Audit: Provisions for an independent audit function to test internal controls. 
   

• Business-Wide Risk Assessment (BWRA): Procedure to identify inherent risks related to customers, countries, and products.
• Risk Categorization: Criteria for classifying customers as Low, Medium, or High risk (e.g., using the EU list of high-risk third countries). 
   

• Identification & Verification: Standard procedures for natural persons and legal entities, including verifying Beneficial Ownership.
• Enhanced Due Diligence (EDD): Mandatory stricter checks for Politically Exposed Persons (PEPs) and transactions over €10,000 for certain sectors.
• Ongoing Monitoring: Regular review of the business relationship and transactions to ensure consistency with the customer’s risk profile. 
   

• Suspicious Activity Reporting (SAR): Internal and external protocols for filing reports with national FIUs without “tipping off” the customer.
• Data Retention: Policy to retain all CDD and transaction records for a minimum of five years post-relationship. 

• Employee Training: Mandatory annual training for all staff involved in AML compliance, agents, and distributors.
• Competency Assessments: Regular evaluation of staff skills and integrity regarding AML/CFT duties. 
   

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