Governance is part of the structure.

AML / CTF

Our framework takes a risk-based approach to anti-money laundering and counter-terrorist financing. Client due diligence, beneficial ownership verification and transaction monitoring support this approach.

Unusual or potentially suspicious activity is reviewed and escalated in accordance with the applicable requirements.

Client Due Diligence

Before establishing a relationship, we seek to understand the client, the purpose of the arrangement and the expected activity. Service access is conditional on compliance review.

Higher-risk circumstances may require enhanced due diligence, additional corroboration and further approval.

KYC / KYB

Identity and address information is required for individuals. Corporate due diligence may include incorporation documents, director and shareholder records, and the ownership structure.

We identify and verify beneficial owners and relevant connected parties to understand who ultimately owns or controls the arrangement.

Source of Funds / Wealth

We may request information and supporting documents concerning the origin of funds and the accumulation of wealth. The evidence required depends on the risk assessment and the proposed activity.

Sanctions Screening

Screening considers sanctions, politically exposed persons and relevant adverse media. Checks cover clients and relevant connected parties and are repeated as appropriate.

Screening results inform the risk assessment and may lead to further enquiries or restrictions.

Ongoing Monitoring

Client relationships are subject to ongoing review. Changes in ownership, business activities or transaction behaviour may trigger a refresh of information or additional due diligence.

Clients may be asked to provide updated documents so that records remain accurate and relevant.

Record Keeping

Due diligence and transaction records are retained in accordance with applicable legal requirements. We cooperate with competent authorities where legally required.

The compliance framework is reviewed periodically and updated when legal or regulatory developments require it.