AML, CTF and KYC Policy Statement

The framework is designed to identify customers and beneficial owners, understand the purpose and expected nature of relationships, assess risk, monitor activity, keep appropriate records and escalate suspicions. Controls are adjusted for the product, customer, geography, delivery channel and transaction profile.

This public statement summarises the approach and does not disclose confidential detection rules, thresholds, reporting decisions or security measures.

Management is responsible for an effective control environment. A designated compliance function maintains policies, advises the business, receives internal escalations, oversees investigations and makes external reports where required. Relevant personnel receive role-appropriate training and are expected to report concerns without delay.

Independent testing, management information and control reviews may be used to assess design and operation. Deficiencies are tracked and remediated according to risk.

• collect and verify identity, date of birth or incorporation, address and contact information;
• identify directors, authorised persons, shareholders, controllers and ultimate beneficial owners where relevant;
• understand occupation or business, account purpose, expected activity and funding arrangements;
• screen customers and related parties for sanctions, PEP exposure and other risk indicators;
• verify ownership of payment methods and request source-of-funds or source-of-wealth evidence; and
• refresh documents and information when they expire, change or no longer support the observed activity.

We may use documents, electronic verification, biometric or liveness tools, databases and direct enquiries. Passing an automated check does not guarantee account approval.

Each relationship may be assigned a risk classification. Higher-risk circumstances can include complex ownership, unusual business models, high-risk locations, PEP connections, adverse information, non-face-to-face onboarding, opaque wealth, third-party funding or activity inconsistent with the stated purpose.

Enhanced measures may include additional identity or corporate evidence, source-of-wealth substantiation, senior approval, more frequent review, tighter limits and increased monitoring. We may decline or exit a relationship if risk cannot be understood or managed.

We screen against sanctions and other restrictions relevant to our operations and service providers. We do not knowingly make services available where doing so would breach an applicable prohibition.

A match or concern may result in delayed processing, rejection, restriction, asset blocking or reporting. We may be legally unable to explain the reason or timing.

• use a payment method held in your own name unless an alternative is approved;
• provide clear evidence of origin, ownership and economic purpose when asked;
• do not use the account as a payment pass-through or for unexplained third-party transfers;
• do not structure transactions to avoid limits or review; and
• ensure descriptions and submitted documents are authentic, complete and consistent.

We may return a payment to its source, limit methods, request additional information, suspend a withdrawal or refuse a transaction where checks are incomplete or risk is unacceptable.

Monitoring considers account, payment, device, behavioural and trading information. Reviews may examine unusual size, speed, frequency, counterparties, locations, economic rationale, related accounts, rapid movement of funds, inconsistent activity and possible exploitation of products or programmes.

We may contact the Client for an explanation and documents. Failure to respond fully and promptly can lead to restrictions or termination.

Personnel must escalate knowledge, suspicion or reasonable grounds for suspicion to the compliance function. The Company may report to a financial-intelligence unit, regulator, law-enforcement agency or other competent authority where required or permitted.

We do not confirm whether a suspicious-activity report exists and will not disclose information where doing so would constitute tipping off, prejudice an investigation or breach law.

Identification, due-diligence, transaction, communication, monitoring and investigation records are retained for the period required by applicable law and legitimate risk-management needs. Records may be supplied to authorised authorities in accordance with law.

Clients must cooperate with reviews and keep profile information current. Questions about document submission may be sent to partners@elibribroker.com; that address must not be used to seek confirmation of confidential reporting decisions.

The framework is maintained with regard to laws and requirements applicable to the Company and its activities, including relevant anti-money-laundering, counter-terrorist-financing and sanctions obligations. The Policy may be updated as risks, products, law and supervisory expectations change.