Legal
AML / KYC Policy
Draft structure for review. Publish only if this is an approved public summary. References to the applicable legislation, supervisory authority and the responsible compliance officer must be confirmed.
1. Policy statement
AVD Gate is committed to preventing money laundering, terrorist financing and sanctions breaches. This summary describes the principles applied in our compliance framework.
2. Customer due diligence
Before onboarding, we identify and verify the merchant, its ultimate beneficial owners and representatives, and assess the business model, expected volumes and markets served.
3. Risk-based approach
Merchants are assigned a risk rating that determines the depth of due diligence, the frequency of reviews and the applicable transaction limits. Enhanced due diligence is applied to higher-risk relationships.
4. Ongoing monitoring
Transactions and merchant activity are monitored for patterns inconsistent with the declared business profile. Unusual activity is escalated for review.
5. Sanctions screening
Merchants, beneficial owners and relevant counterparties are screened against applicable sanctions and watch lists at onboarding and on an ongoing basis.
6. Record keeping
Identification data, due diligence records and transaction records are retained for the periods required by applicable legislation. Retention periods to be confirmed.
7. Reporting and training
Suspicious activity is reported to the competent authority in line with legal requirements. Staff receive periodic training appropriate to their role.
8. Compliance contact
Compliance enquiries can be sent to support@avdgate.com.