Loading
1.1. Finco Group (the "Company") is committed to preventing money laundering, terrorist financing, proliferation financing, and sanctions evasion, and to complying with the AML/CFT requirements of KUNAISA and applicable international standards (including the FATF Recommendations).
1.2. This Policy applies to the Company, its directors, employees, agents, and introducers, and governs the Company's relationship with all Clients. It is a public summary of the Company's internal AML/CFT programme.
2.1. The Company applies a risk-based approach, assessing and rating each Client and business relationship (low / medium / high risk) based on factors including the Client's jurisdiction, profile, source of funds, transaction patterns, and whether the Client is a Politically Exposed Person (PEP).
2.2. The level of due diligence applied is proportionate to the assessed risk.
3.1. The Company verifies the identity of every Client before, or shortly after, establishing the business relationship, and will not permit trading or withdrawals until verification is complete. Minimum information collected includes:
full legal name and any former names;
date and place of birth and nationality;
residential address, verified by a document (utility bill, bank statement, or official document) dated within the last 3 months;
a valid government-issued photo identity document (passport, national ID, or driving licence);
contact details (email and telephone); and
occupation and, where risk-based, source of funds/wealth.
3.2. For legal-entity Clients, the Company additionally collects incorporation and constitutional documents, evidence of good standing, the identity of directors and authorised signatories, and identification of beneficial owners holding [25]% or more [CONFIRM THRESHOLD].
3.3. Documents not in English must be accompanied by a certified translation on request.
4.1. EDD is applied to higher-risk relationships, including PEPs and their close associates, Clients from higher-risk jurisdictions, and unusually large or complex activity. EDD measures include senior-management approval to onboard or continue the relationship, establishing source of funds and wealth, and closer ongoing monitoring.
5.1. The Company screens Clients and, where relevant, related parties against applicable sanctions lists (including UN, [OFAC/US], EU [CONFIRM LISTS]) and PEP databases at onboarding and on an ongoing basis.
5.2. The Company will not establish or maintain a relationship with a sanctioned person, and will not provide services to persons in Restricted Jurisdictions (as defined in the Client Agreement).
6.1. The Company monitors the business relationship and transactions on a risk basis to ensure activity is consistent with the Client's profile and known source of funds, and uses automated and manual tools to detect unusual or suspicious patterns.
6.2. Indicators of suspicion include, without limitation: deposits with no corresponding trading activity ("pass-through" use); third-party funding; mismatches between the payer and the account holder; rapid movement of funds; use of multiple accounts; reluctance to provide information; and use of anonymising methods.
6.3. Crypto-asset funding. Where Clients fund by cryptocurrency, the Company applies blockchain-analytics and wallet-screening controls to assess the provenance and risk of deposited assets. It may reject, freeze or return deposits linked to high-risk or unlawful sources (for example, sanctioned addresses, darknet markets, mixers/tumblers, or fraud), and applies enhanced source-of-funds scrutiny where warranted. Crypto-asset transfers, deposit addresses and counterparties may be recorded for monitoring and reporting purposes. [Confirm virtual-asset obligations, including any Travel Rule expectations, with KUNAISA.]
7.1. Deposits and withdrawals must, so far as possible, be made through the same method and in the name of the Client. Third-party funding is not accepted; where received, funds are returned to source. Card and payment rules are set out in the Regulations for Non-Trading Operations.
8.1. Where an employee suspects money laundering or terrorist financing, they must report internally to the Money Laundering Reporting Officer (MLRO). The MLRO evaluates each report and, where appropriate, files a Suspicious Transaction/Activity Report with the relevant Financial Intelligence Unit [NAME THE FIU / KUNAISA CHANNEL].
8.2. The Company and its staff must not "tip off" any Client that a report has been or may be made. The Company may suspend or delay a transaction, freeze an account, or terminate a relationship where required to comply with its obligations, without incurring liability for doing so.
9.1. The Company appoints a Money Laundering Reporting Officer (MLRO)/Compliance Officer with responsibility for the AML/CFT programme. Contact: [MLRO NAME / compliance@viriora.com].
9.2. All relevant staff receive AML/CFT training on joining and at least annually. Introducers and agents are required to observe this Policy.
10.1. The Company retains CDD records, account files, and transaction records for at least [5 / 7] years after the end of the relationship or the date of the transaction, whichever is later, as required by applicable law [CONFIRM PERIOD], and makes them available to KUNAISA and competent authorities on request.
11.1. The Company may refuse to open an account, refuse or reverse a transaction, freeze funds, or terminate a relationship where it cannot complete CDD, where it suspects financial crime, or where required by law. Refusal to perform a suspicious transaction does not give rise to liability on the part of the Company.
Finco Group · Regulated by KUNAISA, Licence No. FX0042026.