AML, KYC and sanctions statement

We take a risk-based approach, following the recommendations of the Financial Action Task Force (FATF). Our compliance programme is overseen by our Money Laundering Reporting Officer.

Before opening any account, we:

• confirm the identity of the applicant and, for businesses, of the people who own or control the business and the people who will use the account
• confirm addresses
• understand the purpose of the account and the payments expected through it
• confirm the source of funds and, where the risk calls for it, the source of wealth
• screen applicants and connected people against sanctions lists and lists of politically exposed persons

Where the risk is higher, for example for politically exposed persons, we carry out enhanced checks and a senior member of staff approves the account.

We monitor payments throughout the life of every account and ask questions when a payment does not fit what we know about the client. We update client information regularly and when circumstances change.

We screen clients, connected people and payments against the sanctions lists of the United Nations, the United States (OFAC), the United Kingdom and the European Union.

We do not accept applicants, and do not make or receive payments, connected with:

• countries, persons or entities subject to sanctions under any of those lists, where the sanctions prohibit the relationship or payment
• jurisdictions on the FATF list of high-risk jurisdictions subject to a call for action

"Connected with" includes residence, nationality, place of incorporation, ownership, control and the source or destination of funds.

• Money service businesses, payment institutions and other businesses that hold or transfer money for others
• Accounts in false names, or for anyone whose identity we have not verified
• Shell banks, or businesses that act for shell banks
• Clients who do not provide the information we ask for
• Arms, ammunition and military goods
• Cannabis and other controlled substances
• Dealers in precious metals and stones, unless we approve them after enhanced checks
• Companies whose ownership cannot be traced to real people, including companies with bearer shares
• Businesses with no real activity or physical presence

We accept some types of business that carry a higher risk of money laundering, including crypto-asset businesses, gambling operators and adult entertainment businesses, only after enhanced checks. These include evidence that the business holds any licence or registration its activity requires, and a review of its own anti-money-laundering controls. We may apply lower payment limits or closer monitoring to these accounts.

We may decline an application, refuse or delay a payment, or close an account where we are not satisfied with the information we hold, or where the law requires it. We may not always be able to give our reasons.

We report suspicious activity to the competent financial intelligence unit, as the law requires. We are not allowed to tell a client that a report has been made.

We keep identification and transaction records for seven years after the end of the client relationship.

Compliance teams at banks, payment counterparties and auditors may contact us at [email protected]. We provide our licence details and corporate documents on request as part of due diligence.