AML Policy

1. Our commitment

Moving money across borders carries a real risk of being used for crime. Zeltz treats preventing that as a condition of operating, not an administrative overhead. This statement summarises the controls we apply. It is a public summary of our internal financial crime framework, not the framework itself.

2. Legal framework

We are [regulatory status, regulator and reference number] and operate under [applicable AML legislation]. Our framework is approved by our board and reviewed at least annually, and after any material change in our business or in the law.

3. Risk-based approach

We assess the money laundering and terrorist financing risk of our business and apply controls proportionate to it. Our assessment considers the countries we serve, the corridors we operate, our customer base, the products we offer and the delivery channels we use. Higher risk attracts more scrutiny, more evidence and, where appropriate, senior sign-off.

4. Customer due diligence

Before a customer can transact we:

• identify them and verify that identity from independent, reliable sources;
• identify beneficial owners and controllers for business customers;
• establish the purpose and intended nature of the relationship; and
• confirm they are not acting for an undisclosed third party.

We do not offer anonymous accounts. Due diligence is refreshed periodically and whenever activity changes materially or we have doubts about information previously supplied.

5. Enhanced due diligence

Enhanced measures apply to higher-risk relationships, including politically exposed persons and their close associates, customers connected to higher-risk jurisdictions, unusually complex or large transactions, and any pattern with no apparent economic or lawful purpose. These measures include establishing source of funds and source of wealth, and obtaining senior management approval for the relationship.

6. Sanctions screening

Customers, beneficiaries and payments are screened against applicable sanctions lists, including [applicable sanctions regimes], at onboarding, on an ongoing basis, and before a payment is released. Screening lists are kept current. A confirmed match is blocked and reported as the law requires. We do not process payments to or from sanctioned persons, entities or territories.

7. Transaction monitoring

Activity is monitored against the expected profile of the customer. Monitoring looks for patterns associated with laundering, including structuring below thresholds, rapid movement of funds, transfers inconsistent with a stated purpose, and unexplained links between apparently unrelated customers. Alerts are investigated by trained staff, and the outcome of each investigation is documented.

8. Reporting suspicious activity

Where we know or suspect that funds are the proceeds of crime or relate to terrorist financing, we report to [financial intelligence unit]. We may be legally prohibited from telling a customer that a report has been made, and we will not do so where that prohibition applies. Reporting obligations override our commercial interest in keeping a customer.

9. Record keeping

Identification evidence, due diligence records, transaction records and investigation outcomes are retained for [retention period] from the end of the relationship or the date of the transaction, and are available to competent authorities on lawful request. See our Privacy Policy for how that information is handled.

10. Governance and training

Responsibility for the framework sits with [MLRO name or role], our Money Laundering Reporting Officer, who has direct access to the board and the authority to block or exit a relationship. All staff receive financial crime training on joining and at least annually, with additional training for roles in onboarding, monitoring and payments. The framework is subject to independent review.

11. Working with authorities

We cooperate fully with regulators and law enforcement, and respond to lawful requests for information within the timeframes required.

12. Contact

Compliance enquiries, including requests from other regulated firms: [email protected].