Anti-Money Laundering & Counter-Terrorist Financing Policy

Our commitment

Invest Consult Europe Ltd and its affiliates ("Invest Consult Europe", "we") are committed to preventing the use of our services for money laundering, terrorist financing, sanctions evasion, fraud, tax evasion and other financial crime. We apply a risk-based approach informed by the FATF Recommendations and the laws of the jurisdictions in which we operate [confirm applicable regimes and standards].

1. Scope

1. This policy applies to all Invest Consult Europe entities, directors, employees, contractors and agents, and to every client, product and corridor, including trade payments, FX conversion, crypto settlement and digital-asset investment.
2. It supplements our Terms of Service and Privacy Policy.

2. Governance

1. Our board approves this policy and ensures adequate resources for compliance.
2. A senior Compliance Officer / MLRO (Marco Notarnicola, info@aerapass.com) is responsible for the AML programme, monitoring, and reporting to authorities, and has direct access to the board.
3. The programme is reviewed at least annually and independently tested [internal audit / external reviewer].

3. Risk-based approach

1. We assess risk at enterprise and client level, considering client type and ownership, business activity, source of funds, geography, products used, delivery channel and transaction patterns.
2. Corridors involving higher-risk jurisdictions, cash-intensive or high-value-goods sectors, complex ownership, politically exposed persons, and crypto-asset settlement receive enhanced scrutiny.
3. Risk ratings are reviewed periodically and whenever new information arises.

4. Customer due diligence (KYC / KYB)

1. We verify the identity of every client before opening an account or executing a transaction, using documents and independent data sources and digital verification tools.
2. For businesses we identify and verify directors, authorised users and beneficial owners (individuals holding [25]% or more, or otherwise exercising control), and understand ownership and control structure and the nature of trade.
3. We collect information on the expected purpose of the account, trade counterparties, goods and corridors, and source of funds and wealth, as proportionate to risk.
4. Enhanced due diligence applies to higher-risk clients, including senior management approval, additional documents, and closer monitoring.
5. We do not open anonymous or fictitious accounts, and we do not onboard shell banks.
6. Where we rely on another regulated party for due diligence, it must be subject to equivalent obligations and give us immediate access to records. We remain responsible for compliance.

5. Politically exposed persons

1. We screen for PEPs, their family members and close associates at onboarding and on an ongoing basis. PEP relationships require enhanced due diligence, source-of-wealth verification and senior approval.

6. Sanctions screening

1. Clients, beneficial owners, counterparties, beneficiaries, vessels and wallet addresses are screened against applicable sanctions lists, including those of the UN, [OFAC, EU, UK] and relevant local authorities [confirm].
2. We do not process transactions that would breach applicable sanctions, and we may freeze funds and report where required.

7. Ongoing monitoring

1. We monitor accounts and transactions for activity inconsistent with the client's profile, using automated rules and manual review.
2. Trade-related red flags include invoices or documents that appear inconsistent with the goods, quantities or prices; over- or under-invoicing; unexplained third-party payers or beneficiaries; unusual routing; and payments unrelated to stated trade activity.
3. We may request supporting documents (contracts, invoices, bills of lading, customs records) before or after processing, and may delay, block or refuse a payment pending review.
4. Client information is refreshed on a risk-based schedule.

8. Digital assets

1. Crypto settlement and investment services are subject to the same standards as fiat services.
2. We screen wallet addresses and transaction flows with blockchain-analytics tools, verify source of funds, and apply the FATF travel-rule requirements where applicable by collecting and transmitting required originator and beneficiary information.
3. We may refuse or return transfers linked to mixers, sanctioned addresses, darknet markets or other high-risk exposure.

9. Suspicious activity reporting

1. Employees must report suspicions of money laundering, terrorist financing or other crime internally without delay. The Compliance Officer assesses each report and files suspicious activity or transaction reports with the competent authority where required.
2. Staff must not tip off clients or third parties that a report has been made or that an investigation is under way.
3. We cooperate with lawful requests from regulators and law enforcement.

10. Record keeping

1. We keep identification records, transaction records, due-diligence files, monitoring and reporting records for at least [five (5)] years after the end of the relationship or the transaction, or longer where the law requires, in line with our Privacy Policy.

11. Training and awareness

1. All relevant staff receive AML/CFT training at onboarding and at least annually, with additional role-specific training for compliance, onboarding and payments teams. Attendance is recorded.

12. Prohibited clients and activities

1. We do not provide services to sanctioned persons or entities, shell banks, or anyone refusing to provide required information.
2. We do not support illegal activity, including trafficking, terrorism, arms proliferation, unlicensed gambling, child exploitation, or tax evasion.
3. We may decline, suspend or terminate any relationship at our discretion where risk is not acceptable.

13. Whistleblowing

1. Staff and third parties may report concerns confidentially to info@aerapass.com. We prohibit retaliation against good-faith reporters.

Contact

Compliance Officer / MLRO: Marco Notarnicola — info@aerapass.com
Invest Consult Europe Ltd, 21 Stonelea Court, Meanwood, Leeds, England, LS7 2UH (Company No. 09371842)