Anti-Money Laundering Policy

We do not knowingly conduct business with money launderers, terrorists or sanctioned individuals. Our programme is built on four pillars: customer due diligence, transaction monitoring, suspicious activity reporting and staff training.

• Identity verification at registration thresholds (€2,000 cumulative deposit or earlier where risk indicates).
• Enhanced Due Diligence for high-risk customers, including source-of-wealth checks.
• PEP and sanctions screening at onboarding and on a continuous basis.

Automated rules flag unusual patterns such as rapid deposits-and-withdrawals without play, structuring around limits, and inconsistencies with the customer's profile. Flagged transactions are reviewed by trained analysts within 24 hours.

Suspicious activity reports are filed with the relevant financial intelligence unit. We do not tip off customers about reports under any circumstance.

Transaction and KYC records are retained for a minimum of five years after the end of the customer relationship, in line with regulatory requirements.

All customer-facing and operations staff complete AML training on joining and annually thereafter. The MLRO reports to the board quarterly.