AML and KYC policy
We are required by law to know who our clients are, where their money comes from, and who ultimately controls any company we form. This page explains what we check, how we handle the results, and what happens when checks are not passed.
1. Why we check
Anti-money-laundering (AML) and counter-terrorist-financing (CFT) laws require us to verify clients before we act and to keep records of those checks. These checks apply to every enquiry we accept, whatever the size of the engagement or the jurisdiction.
2. Who we check
- The client and any company or trust that is part of the structure.
- Every director, company secretary and authorised signatory.
- Every beneficial owner: any individual who owns or controls 25% or more, or who controls the company in another way.
- Anyone who sends payment on the client's behalf.
3. What we check
- Identity: a valid passport or national ID, checked against the document and the person.
- Address: proof of residential and business address dated within the last three months.
- Source of funds and source of wealth: how the money to pay for the engagement was earned or obtained.
- Business activity: what the company will do, where, and with whom.
- Sanctions, watchlists and politically exposed person (PEP) status. [Lists and thresholds to be confirmed by counsel.]
- Adverse media: public reports that suggest financial crime, fraud or corruption.
4. Risk rating
Each client receives a risk rating before we accept the engagement. Clients rated high risk receive enhanced checks, which can include additional documents, a senior review, and a longer timeline. We may decline a client whose risk we cannot manage within our policy.
5. How payments are accepted
- Payments must come from a bank or payment account in the client's own name or in the name of the company being formed.
- We do not accept cash or cryptocurrency for the minimum payment or for our fees.
- Payments from third parties are not accepted unless we have approved the third party in writing after checks.
6. Ongoing monitoring
We monitor client relationships for changes that affect risk, including changes in ownership, directors, activity, or payment patterns. We may ask for updated documents at any time, and clients must respond within the time we set.
7. Screening outcome and the $700 screening fee
If our identity or legal review does not approve the engagement after the minimum payment has been made, we keep $700 as a screening fee and refund the remaining amount to the payment source you used. The rule is the same as in our Terms and conditions and Refund policy.
8. Reporting suspicious activity
The law may require us to report suspicious activity to the authorities. In many cases we are not allowed to tell the client that a report has been made, and we are not required to explain our decision.
9. Staff training
Our staff receive training on AML and CFT obligations and on how to recognise and escalate suspicious activity. Our compliance lead reviews this policy at least once a year. [Review cycle to be confirmed by counsel.]
10. Record keeping
We keep identity, screening and transaction records for the period required by law. When that period ends, we delete or anonymise the records unless the law requires us to keep them longer.
11. Contact
Questions about our checks: sales@offshoreglobe.com.