Compliance & KYC
AML/CTF, sanctions controls, onboarding standards and ongoing KYB governance
Effective Date: 1 April 2026
Version: 1.0
Policy Owner: Compliance Department
Contact: [email protected]
Review Cycle: At least annually or when required by law/regulation
1. AML/CTF Framework
FIDERE applies a risk-based AML/CTF program for client onboarding and ongoing monitoring.
Control measures include customer due diligence (CDD), beneficial ownership verification, transaction monitoring, and suspicious activity escalation.
Enhanced due diligence (EDD) may be required for high-risk clients, complex ownership structures, and unusual transaction patterns.
AML/CTF controls are reviewed periodically to align with legal, regulatory, and operational risk requirements.
2. KYC/KYB Documentation
Individual onboarding may require identity verification, address proof, source of funds/wealth evidence, and additional supporting documents.
Corporate onboarding may require incorporation records, constitutional documents, director/shareholder registers, UBO information, and business profile.
FIDERE may request supplementary documents where needed to satisfy legal, regulatory, operational, or risk requirements.
Document acceptance and re-validation requirements may differ by jurisdiction, product, channel, and client risk profile.
3. Typical Corporate KYB Pack
Certificate of incorporation, business registration, constitutional documents, and proof of registered address.
Director and authorized signatory information, board resolutions or mandates, and ownership charts up to ultimate beneficial owners.
Business model description, expected transaction profile, source of funds narrative, and key counterparty/market exposure details.
Where applicable, audited financials, tax residency information, and licensing or regulatory filings relevant to the proposed activity.
4. Sanctions, PEP and Ongoing Review
Clients and relevant connected parties may be screened against sanctions and watchlists during onboarding and periodically thereafter.
Politically exposed person (PEP) status and adverse media may be considered as part of risk assessment.
FIDERE reserves the right to delay, decline, restrict, or terminate services where risk acceptance criteria are not met.
Material changes in ownership, control, transaction behavior, geography, or business activities may trigger re-screening and profile refresh.
5. EDD Triggers and Risk Acceptance
EDD may apply to high-risk jurisdictions, opaque ownership chains, unusual transaction velocity, or mismatch between stated and observed activity.
Additional checks may include independent corroboration of source of wealth, senior management approval, and tighter transaction controls.
FIDERE may reject or exit relationships involving unacceptable sanctions, legal, fraud, or reputational risk.
6. Compliance Cooperation and Recordkeeping
FIDERE may retain onboarding and transaction records for the period required by applicable law and regulation.
Where legally required, FIDERE may cooperate with regulators, law enforcement, or competent authorities.
Service availability remains subject to successful compliance review and ongoing risk monitoring.
Clients are responsible for promptly providing accurate updates when there are material changes to corporate structure, controllers, or business operations.
Document Control
Approver: Authorized Management
Next Review Date: 1 April 2027
Change Log: Initial release