Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy
Effective Date: 1 January 2025
Approved by the Board of Directors
1. Policy Statement
Acadace LTD (“the Company”) is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. The Company fully adheres to applicable laws and regulations in its jurisdiction of operation, and aligns its practices with Financial Action Task Force (FATF) recommendations, EU AML Directives, and other relevant international standards.
The objective of this policy is to prevent the Company from being misused for money laundering, terrorist financing, or any illicit financial activities.
2. Scope
This policy applies to:
- All employees, directors, and agents of Acadace LTD.
- All customers and counterparties, including individuals and corporate entities.
- All products and services, including the rental and management of CRM systems, fintech solutions, and advisory services to crypto market participants.
3. Customer Due Diligence (CDD)
3.1 Identification and Verification
- All customers must undergo identification and verification before services are provided.
- For individuals: government-issued ID and proof of address (not older than 3 months).
- For corporates: certificate of incorporation, company registration documents, M&A or equivalent, details of directors/shareholders/UBOs, and proof of business address.
3.2 Risk-Based Approach
- Customers are classified as Low, Medium, or High Risk based on geography, business, transaction patterns, and involvement in cryptocurrency.
- Enhanced Due Diligence (EDD) applies to PEPs, high-risk jurisdictions, and complex ownership structures.
4. Ongoing Monitoring
- Customer relationships are subject to ongoing monitoring.
- Transactions are monitored for unusual activity, including high volume/frequency or crypto-to-fiat flows.
- Monitoring is reviewed monthly by the Compliance Department.
5. Suspicious Activity Reporting (SAR)
- Employees must escalate unusual activity to the MLRO immediately.
- The MLRO files SARs with the Financial Intelligence Unit (FIU).
- Tipping off the customer is strictly prohibited.
6. Record Keeping
- Customer identification and transaction records retained for at least 7 years.
- Records stored securely in compliance with GDPR and relevant data protection laws.
7. Training & Awareness
- Annual AML/KYC training for all employees.
- Training covers obligations, detection of suspicious activity, and reporting procedures.
- Records of training maintained by Compliance Department.
8. Roles & Responsibilities
- Board of Directors: Oversees AML framework and approves policy updates.
- Money Laundering Reporting Officer (MLRO): Manages AML/KYC operations and regulator liaison.
- Employees: Must comply with AML/KYC and escalate issues.
9. Sanctions & Prohibited Relationships
- No relationships with shell banks or anonymous accounts.
- No clients from sanctioned jurisdictions (UN, EU, OFAC).
- No clients unwilling or unable to provide KYC documentation.
10. Policy Review
The policy is reviewed annually or upon regulatory changes. Updates require Board approval.
Declaration
Acadace LTD is committed to preventing money laundering, terrorist financing, and other financial crimes. This policy reflects our strong stance on transparency, ethical conduct, and regulatory compliance.
Approved by:
_________________________
Stelios Miltiadous
Director, Acadace LTD
Date: 1 January 2025