Money Laundering is the process by which criminals attempt to hide and disguise the true origin and ownership of the proceeds of their criminal activities and thereby have these funds enter the normal economy to make it seem as if they have been obtained legitimately. Terrorist Financing is the act of unlawfully and willingly providing or collecting funds (whether directly or indirectly) with the intention that they should be used or, in the knowledge that they are to be used, in support of an act of terrorism. Both are global problems that compromise the security and effectiveness of all financial systems – whether crypto finance or traditional banking, undermine economic development and damage societies.

When setting its Policy, the Company has taken into account relevant legal and regulatory requirements as updated from time to time in the United Kingdom and elsewhere. The Company recognises that failure to comply with this Policy can have serious consequences for the Company, including criminal and civil fines, public censure and significant reputational and regulatory damage.

We offers AML services to financial institutions such as banks, estate agents, insurance providers, crypto-asset providers and solicitors. Such services include KYC and name screening as well as document verification. As part of the discharge of its services the Company is committed to denying terrorists and criminals access to the financial system and to complying with all applicable Anti-Money Laundering and Counter Terrorist Financing laws and regulations. This document sets out the Company’s Policy on AML and Counter Terrorist Financing.

The Company operates in many different jurisdictions with many different Customers and is therefore subject to different legal requirements and regulatory expectations when determining which proceeds-generating crimes are money-laundering offences. This policy therefore sets out the minimum applicable requirements in relation to AML which these jurisdictions must apply. The Company will comply with requirements set out in law or regulations and consider regulatory expectations in each country where it operates, where those requirements or expectations go beyond the standards of the Company AML Policy.

All Staff are responsible for complying with this Policy, all applicable laws and regulations, and for ensuring the effective management of money laundering risk within the scope of their direct organisational responsibilities. No Staff may be involved in any manner in any activity intended to avoid or circumvent the Company’s AML Policy. Any breach of this Policy may, amongst other things, lead to disciplinary action and/or loss of employment.

The Company has adopted a risk based approach to AML. For the Customers to whom the Company provides services, this is demonstrated through the categorisation of their individual Clients during initial KYC checks and the subsequent monitoring of transactions that is then deployed. In general the Company takes the view that it has no appetite for breaches in laws and regulations related to Financial Crime, recognising that whilst incidents are unwanted, they cannot be entirely avoided.

Similarly, when providing services to Customers, the Company will establish KYC Procedures to identify and manage money laundering risk of the Customer’s Clients and ensure that the Customer reasonably knows its Client at the time of onboarding, and through the life cycle of the Client relationship.