KYC & AML policy

The company is committed to preventing money laundering, terrorist financing, tax evasion, corruption and sanctions circumvention. The following policy applies to all members, employees and mandated business partners of the company.

1. Customer identification (KYC)

• Corporate clients: registry extract, articles of incorporation, proof of registered address, and evidence of the representatives' signing authority.
• Individuals: government-issued photo identification and proof of residential address not older than three months.
• No business relationship is entered into on an anonymous, nominee-only or undocumented basis.

2. Beneficial ownership

• Identification of all natural persons holding, directly or indirectly, 25% or more of the ownership or voting rights, or otherwise exercising control.
• Written beneficial-ownership declaration, supported by identification documents and an ownership chart where structures are layered.

3. Sanctions, PEP and adverse-media screening

• Screening of clients, beneficial owners, counterparties and, where relevant, logistics providers against EU, UN, UK (OFSI) and US (OFAC) sanctions lists.
• Politically exposed persons are subject to enhanced due diligence and require management approval before onboarding.
• Ongoing re-screening for the duration of the business relationship.

4. Source of funds and purpose of the transaction

• Documented understanding of the commercial rationale, the source of funds and the expected payment flows of each mandate.
• Transactions without an evident economic purpose, or with unusual routing of funds, are declined.

5. Payments

• Fees are settled exclusively by bank transfer to the company's own accounts.
• No cash acceptance, no third-party payments, no pass-through of client funds and no settlement in anonymous instruments.

6. Prohibited activities

• Business with sanctioned persons, entities or embargoed jurisdictions.
• Trade in weapons, munitions, dual-use goods subject to licensing, narcotics, protected species, or any other restricted or illegal goods.
• Structures whose evident purpose is concealment of ownership or tax evasion.
• Any activity requiring a financial-services licence the company does not hold.

7. Record keeping

• Complete mandate files, identification records and transaction documentation are retained for at least five years after the end of the business relationship.
• Records are made available to banks, auditors and competent authorities upon lawful request.

8. Governance and reporting

• Compliance responsibility rests with the management of the company; onboarding decisions for higher-risk relationships require documented approval.
• Suspicions of money laundering or terrorist financing are escalated internally and reported to the competent authority where required by applicable law.
• The policy is reviewed at least annually and after material regulatory change.

9. Contact for compliance enquiries

Financial institutions, auditors and counterparties may direct compliance and documentation requests to info@tc-management-services.com.