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AML/KYC Policy

Last updated: 10 September 2026

The Company adheres to anti-money-laundering (AML) and counter-terrorist-financing (CFT) principles and performs mandatory verification of all clients (KYB — Know Your Business).

1. Company verification (KYB)

Every company is verified before an account is opened. We request: constitutional documents, an up-to-date trade registry extract, ownership structure details, information on beneficial owners (holding 25% or more), documents of directors and authorised representatives and, where necessary, licences and financial statements.

2. Sanctions and PEP screening

Companies, their beneficial owners and representatives are screened against international sanctions lists and lists of politically exposed persons (PEP). Cooperation with sanctioned persons is excluded.

3. Ongoing monitoring

We monitor client transactions for unusual activity and may request additional documents and explanations of the source of funds at any point of the relationship.

4. Right of refusal

The Company may decline to open an account, suspend transactions or terminate the relationship if verification fails, documents are not provided, or signs of suspicious activity are identified.

5. Reporting

Where suspicious transactions are identified, the Company is obliged to report them to the competent authorities in accordance with applicable law, without notifying the client where the law so requires.

6. Record keeping

Documents and data obtained during KYB are retained for at least 5 years after the business relationship ends, unless the law requires a longer period.

7. Staff training

Company employees receive regular AML/CFT training and must follow internal control procedures.