AML & counter-terrorist financing policy

We maintain a risk-based anti-money-laundering (AML) and counter-terrorist-financing (CTF) programme aligned with Financial Action Task Force recommendations and the rules of the jurisdictions where we operate. The programme is owned by our Money Laundering Reporting Officer and reviewed at least annually by our board.

We verify the identity of every customer before opening an account and apply enhanced due diligence for higher-risk relationships — including politically exposed persons, sanctioned jurisdictions, and complex ownership structures.

Transactions are monitored in real time against behavioural and rules-based models. Alerts are reviewed by trained analysts, and suspicious activity is reported to competent financial intelligence units as required by law.

All employees complete AML/CTF training at onboarding and annually thereafter. Role-based training is provided to teams handling customer onboarding, transaction monitoring, or investigations.

We retain KYC records, transaction data, and case files for at least five years from the end of the customer relationship, or longer where required by local law.