Protect against money laundering and know your customer policy (AML & KYC) 

Private Banking Service AML/KYC Policy 

1.Purpose and Scope 

This Private Banking Service AML/KYC Policy (the “Policy”) establishes the standards and procedures  for onboarding, ongoing monitoring, and compliance with applicable anti-money laundering (AML) and  countering the financing of terrorism (CFT) laws and regulations. It aims to safeguard the integrity of our  private banking services by effectively managing AML and CFT risks associated with high-net-worth  clients, complex structures, and cross-border activity, while maintaining the highest standards of  confidentiality and discretion. 

This Policy applies to all private banking clients, relationship managers, officers, employees, directors,  and contractors involved in providing private banking services.

2.Regulatory Framework and Standards 

Our AML/KYC procedures align with: 

Financial Action Task Force (FATF) Recommendations, including those tailored to private banking and  high-risk clients. 

United States Bank Secrecy Act (“BSA”) and FinCEN guidance. 

European Union AML Directives (AMLD5/AMLD6) and Markets in Crypto-Assets Regulation (MiCA). Sanctions regimes from OFAC, UN, EU, and UK authorities. 

Travel Rule obligations for virtual asset transfers. 

Industry best practices emphasizing client confidentiality and risk mitigation.

3.Governance and Oversight 

The Private Banking AML Committee, comprising senior compliance officers and relationship managers,  oversees implementation. 

Regular audits, reviews, and independent assessments ensure ongoing compliance. Confidentiality protocols protect client data, activity, and information. 

The compliance team has the authority to suspend or restrict client accounts when AML/CFT concerns  arise, ensuring discretion and adherence to privacy standards.

4.Risk-Based Client Assessment 

Clients are evaluated based on: 

Source and legitimacy of wealth and funds. 

Jurisdictional risk, with particular attention to high-risk or non-cooperative states. Ownership and control structures, including trusts and offshore entities. 

Transaction size, complexity, and cross-border activity. 

Use of privacy-enhancing virtual assets or obfuscation techniques. 

Clients are categorized into tiers (see Appendix 1), with corresponding due diligence and monitoring  requirements.

5.Customer Due Diligence (CDD) 

Verification of client identity through independent, reliable documentation. 

Verification of beneficial ownership and control structures. 

Screening against sanctions, politically exposed persons (“PEPs”), and adverse media. Continuous monitoring of client activity and transactions. 

No accounts with fictitious or anonymous identities are permitted, respecting privacy and regulatory  standards.

6.Enhanced Due Diligence (EDD) 

Applied to:

Clients from high-risk jurisdictions. 

Clients with complex or opaque ownership structures. 

PEPs or their close associates. 

Clients engaged in high-value or unusual transactions. 

EDD measures include: 

Additional documentation such as trust deeds, offshore registration details. 

Independent verification of source of wealth and funds. 

Enhanced transaction monitoring with specialized analytics. 

Senior compliance review and approval before onboarding or transaction authorization.

7.Client Identification and Ongoing Monitoring 

Relationship managers conduct in-depth interviews to understand clients’ backgrounds. Regular reviews are performed at least annually or when risk indicators change. The process emphasizes confidentiality and respects client privacy, balancing AML obligations with  discretion.

8.Transaction Monitoring & Blockchain Analytics 

Deployment of advanced, risk-based transaction monitoring systems. 

Focus on large, complex, or suspicious transactions. 

Special attention to cross-border transfers, privacy coins, mixers, and obfuscation services.

9.Travel Rule and International Transfers 

Strict adherence to Travel Rule requirements. 

Collection and verification of originator and beneficiary information for high-value transfers. Discretionary restrictions or blocks are applied where compliance cannot be assured, maintaining  confidentiality.

10.Asset Transfers and Withdrawals 

Transfers are only made to verified accounts or blockchain addresses under the client’s control. Third-party withdrawals require additional verification and approval. 

Internal transfers are monitored for sanctions, activity, and compliance with Travel Rule obligations.

11.Sanctions and Prohibited Jurisdictions 

No services are provided to sanctioned persons or entities. 

Enhanced screening for clients from high-risk or non-cooperative jurisdictions. List updates are dynamic, aligned with official sanctions lists.

12.Suspicious Activity Reporting 

Suspicious activity may trigger restrictions, transaction blocks, or account termination. Suspicious Activity Reports (“SARs”) or Suspicious Transaction Reports (“STRs”) are filed  confidentially with relevant authorities. 

The Company strictly adheres to anti–tipping-off regulations, safeguarding client confidentiality.

13.Recordkeeping 

All client identification, transaction, and investigation records are securely maintained. Records are retained for at least 7 years, in accordance with legal and regulatory requirements.

14.Confidentiality & Client Privacy 

All AML/KYC activities are conducted in strict confidence. 

Disclosures are permitted only as legally required or with client consent. 

Internal AML investigations and decisions are not disclosed to clients unless necessary. 

15.Policy Enforcement & Review 

 This Policy is incorporated into the client relationship agreement. 

It is reviewed and updated at least annually or in response to regulatory or industry developments.

Enforcement emphasizes discretion, client confidentiality, and compliance with industry best practices. 

Appendix 1: Customer Due Diligence Tiers for Private Banking Service