Sterlingreen (“Company”) is fully committed to complying with all applicable anti-money laundering (AML) and know your customer (KYC) regulations. This policy outlines the procedures and internal controls established to prevent financial crimes such as money laundering, terrorist financing, and fraudulent activities.
1. Purpose and Scope
Objective
This policy ensures that Sterlingreen operates in strict accordance with relevant AML and KYC laws and maintains a secure and transparent business environment.
Applicability
The policy applies to all Sterlingreen personnel, including employees, management, and affiliated entities.
2. Customer Identification Requirements
Verification Process
Before establishing any customer relationship, Sterlingreen requires valid identification documentation. Acceptable forms include government-issued IDs, passports, or driver’s licenses.
Information Collected Includes:
- Full name
- Date of birth
- Residential address
- Nationality
- Contact details (phone/email)
- Official ID or tax identification number
3. Risk-Based Approach
Client Risk Classification
Each customer undergoes a risk assessment based on their geographic location, transactional behavior, and business profile. Clients are categorized into low, medium, or high-risk tiers.
Enhanced Due Diligence (EDD)
Customers identified as high risk are subject to stricter verification procedures, including collection of additional documents, detailed background checks, and heightened monitoring.
4. Continuous Monitoring
Transaction Review
Client transactions are continuously reviewed to ensure they align with expected patterns and profiles. Any deviation or irregular activity is flagged for further analysis.
Periodic Updates
Customer data and risk profiles are reviewed on a regular basis to ensure compliance with updated regulations and internal standards.
5. Suspicious Activity Reporting
Internal Reporting
All employees are obligated to report unusual or potentially suspicious activity to the designated AML Compliance Officer without delay.
External Reporting
Where required, Sterlingreen will notify regulatory bodies and submit Suspicious Activity Reports (SARs) in accordance with applicable laws.
6. Documentation and Record Retention
Retention Duration
Client-related documentation, including identity verification and transaction history, is securely retained for a minimum of five years following the end of the business relationship.
Access Control
Records are stored securely and are accessible only to authorized personnel.
7. Employee Training and Awareness
Training Program
Employees receive regular AML and KYC training that includes identifying suspicious activity, understanding regulatory requirements, and following internal procedures.
Ongoing Compliance Knowledge
All staff are expected to stay up-to-date on changes in regulations and internal compliance updates.
8. Oversight and Accountability
Compliance Officer
A designated AML Compliance Officer oversees the Company’s AML and KYC initiatives, ensures implementation of internal controls, and acts as a point of contact for regulators.
Management Responsibility
Company leadership is responsible for ensuring sufficient resources are dedicated to AML compliance and for regularly evaluating the program’s effectiveness.
9. Restrictions and Prohibited Activities
- Anonymous Accounts: Sterlingreen does not open or manage accounts without verifiable identity information.
- Sanctioned Entities: The Company refrains from engaging with individuals or organizations listed on international sanctions or watchlists.
10. Regulatory Compliance
Adherence to Law
Sterlingreen complies with local and international AML/KYC regulations and fully cooperates with authorized legal investigations and regulatory audits.
Policy Review
This policy is reviewed and updated routinely to reflect regulatory changes and industry standards.
11. Client Responsibilities
Customer Cooperation
Clients are expected to provide accurate, complete information and comply with all verification procedures. Refusal or failure to comply may result in service suspension or account termination.
Sterlingreen upholds the highest standards of regulatory compliance, transparency, and risk prevention. Our AML and KYC policies are a key part of our ongoing commitment to safeguarding the integrity of our operations and protecting our clients and the wider financial ecosystem.