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AML and KYC Policy

Last updated: September 2026

Our position

We are committed to preventing money laundering, terrorist financing, sanctions evasion and tax evasion. We apply a risk-based approach to every client and every transfer, in line with applicable anti-money laundering legislation and the standards of the Financial Action Task Force.

Customer due diligence

  • We identify and verify every buyer, director and beneficial owner before a company is transferred
  • We establish the purpose and intended nature of the business
  • We obtain information on source of funds and, where appropriate, source of wealth
  • We apply enhanced due diligence to higher-risk clients, jurisdictions and politically exposed persons

Screening and monitoring

Clients and connected persons are screened against sanctions, politically exposed person and adverse media lists at onboarding and at intervals afterwards.

What we will not do

  • Transfer a company to an unidentified or anonymous owner
  • Accept payment from unrelated third parties without explanation and verification
  • Assist in concealing beneficial ownership from competent authorities
  • Deal with persons or jurisdictions subject to applicable sanctions

Record keeping and reporting

Due diligence records are kept for at least five years after the end of the relationship. Where we know or suspect money laundering or terrorist financing we report it to the relevant authority, and the law may prohibit us from telling the client.