Anti-Money Laundering Policy

01Purpose, scope and regulatory approach

The purpose of this policy is to protect clients, SB2Markets, payment channels and the wider financial system from misuse. It applies to account applications, client profiles, beneficial owners, authorised representatives, deposits, withdrawals, transfers, trading-related activity and relevant business partners.

The operator applies a risk-based approach. Controls are designed according to applicable law, the nature of the service, client type, product, geography, delivery channel, transaction pattern and other relevant risk indicators. A higher-risk classification does not itself imply wrongdoing, but it may require enhanced checks or closer monitoring.

This public policy summarises the control framework. Detailed thresholds, screening rules, escalation criteria and reporting procedures are confidential to prevent circumvention and preserve the effectiveness of controls.

02Governance and responsibility

Responsibility for financial-crime prevention is assigned through documented roles, approval levels and escalation procedures. Relevant personnel are expected to understand their responsibilities and promptly refer unusual activity to the designated compliance function.

• Senior oversight of the financial-crime risk framework and material control weaknesses.
• A designated compliance function with authority to request information, restrict activity and escalate concerns.
• Separation of duties where appropriate between onboarding, payment handling, account administration and compliance review.
• Periodic review of policies, risk assessments, provider performance and control effectiveness.
• Confidential record keeping for decisions, exceptions, investigations and legally required reports.

03Enterprise and client risk assessment

The operator assesses financial-crime risk at both business and client level. The assessment may consider changes in law, products, payment methods, technology, geography, delivery channels, fraud trends and external risk information.

A client risk rating may be established at onboarding and updated when relevant circumstances change. Factors may include occupation or business activity, expected account use, ownership structure, source of funds, country exposure, sanctions or politically exposed person status, transaction behaviour and the reliability of information provided.

04Identity and customer due diligence

Before providing a service, and at appropriate times afterward, we may collect and verify information sufficient to understand who the client is, who controls the relationship and why the service is required.

1. Identify the individual or legal entity and obtain reliable contact information.
2. Verify identity using appropriate documents, electronic sources or a specialist verification provider.
3. Identify and take reasonable measures to verify beneficial owners and persons exercising control.
4. Understand the purpose and intended nature of the relationship, expected funding method and anticipated activity.
5. Confirm that a representative is authorised to act and verify that representative where required.
6. Assign an appropriate risk classification and determine whether standard or enhanced checks are required.

05Legal entities, beneficial ownership and authority

For a company, partnership, trust, foundation or similar arrangement, we may request constitutional documents, registration details, registered address, business purpose, directors, partners, trustees, settlors, beneficiaries, authorised signatories and ownership information.

A beneficial owner is generally the natural person who ultimately owns, controls or benefits from the entity or arrangement. Where ownership is complex, we may request an ownership chart, supporting registers, financial statements, contracts or other evidence sufficient to understand the structure and control chain.

Nominee, bearer, layered or opaque structures may require enhanced review. We may decline a relationship where beneficial ownership or authority cannot be established to a satisfactory standard.

06Enhanced due diligence and higher-risk relationships

Enhanced due diligence may be applied when a relationship presents elevated risk. The measures selected will depend on the reason for the higher-risk classification and applicable legal requirements.

• Obtaining additional identity, ownership, occupation or business information.
• Establishing source of funds and, where appropriate, source of wealth with supporting evidence.
• Seeking information about expected transaction size, frequency, counterparties and jurisdictions.
• Requiring senior or compliance approval before establishing or continuing the relationship.
• Applying more frequent reviews, lower operational limits or enhanced transaction monitoring.
• Requesting an explanation and documents for specific deposits, withdrawals or unusual activity.

07Politically exposed persons, sanctions and adverse information

Clients, beneficial owners, representatives and relevant counterparties may be screened against sanctions lists, politically exposed person data and credible adverse-information sources. Screening may be performed during onboarding and periodically afterward.

A politically exposed person relationship may require enhanced due diligence, senior approval, source-of-wealth or source-of-funds information and enhanced ongoing monitoring. The same approach may apply to family members and close associates where required by law.

We will not knowingly make services available in breach of applicable sanctions. A potential match may result in delayed processing, information requests, asset restrictions, rejection or reporting to a competent authority where required.

08Source of funds, source of wealth and payment ownership

We may reject or return a payment where ownership is unclear, the payment comes from an undisclosed third party, the stated purpose is inconsistent, required evidence is not provided or the transaction cannot be processed lawfully. Withdrawals may be directed back to an original or verified source where required by law or payment rules.

Source of funds

The origin of the money used for a particular deposit or series of transactions, such as salary, savings, business income, investment proceeds, inheritance or sale of an asset.

Source of wealth

How a person accumulated their overall financial position, such as employment, business ownership, investments, property or inheritance.

Payment ownership

The relationship between the client and the bank account, card, wallet or payment method used to fund or receive money.

Supporting evidence

Documents or reliable records such as statements, payslips, contracts, tax records, sale agreements, probate documents or audited accounts.

09Transaction and relationship monitoring

Account and transaction activity may be monitored manually and through automated rules to identify patterns that are inconsistent with the client profile, expected activity, payment ownership or lawful use of the service.

• Rapid movement of funds without a clear trading or economic purpose.
• Multiple funding sources, third-party payments or unexplained changes in withdrawal destination.
• Activity involving high-risk or restricted jurisdictions, sanctioned parties or unusual counterparties.
• Transactions inconsistent with the client’s stated occupation, business, income or expected account use.
• Attempts to split, disguise, reverse or reroute transactions to avoid controls or reporting thresholds.
• Use of false documents, conflicting information, account takeover indicators or suspected fraud.
• Dormant accounts that become active with unexplained or unusually large activity.

10Suspicious activity, reporting and transaction restrictions

Where facts or circumstances create a suspicion of money laundering, terrorist financing, sanctions evasion or related crime, the matter may be escalated internally and reported to a financial intelligence unit, regulator, law-enforcement body or other competent authority as required by law.

We may delay, reject, block, freeze, reverse or otherwise restrict a transaction or relationship where required or permitted. We may also preserve records and refrain from notifying the affected person when notification could constitute tipping-off, prejudice an investigation or breach a legal direction.

11Record keeping and confidentiality

We retain due-diligence, account, transaction, communication, screening and investigation records for the period required by applicable law and legitimate legal needs. Records may be retained after the relationship ends and may be made available to competent authorities where lawfully required.

Financial-crime records, internal reports, alert logic and authority communications are treated as confidential. Access is limited to personnel and providers with an operational or legal need to know.

12Your responsibilities

Clients and applicants must cooperate with lawful due-diligence requests and must not use the service for another person without disclosure and approval.

• Provide genuine, accurate, complete and current identity, ownership and contact information.
• Use payment methods held in your name or otherwise disclosed and accepted in advance.
• Explain the purpose and source of transactions truthfully and provide reasonable evidence when requested.
• Notify us promptly about changes in ownership, control, residence, occupation, business activity or authorised representatives.
• Do not structure transactions, use nominees or provide misleading information to avoid verification, monitoring or reporting.
• Do not permit another person to control or use an account contrary to the account agreement.

13When services may be refused or ended

We may decline an application, refuse a transaction, limit functionality, close an account or terminate a relationship when required by law or where the financial-crime risk cannot be understood or managed to an acceptable level.

Possible reasons include inability to verify identity or ownership, failure to provide requested information, suspected misuse, sanctions exposure, false documents, unexplained third-party funding, unacceptable geographic risk or a direction from a competent authority. Where legally permitted, any remaining balance will be handled according to the client agreement and verified payment instructions.

14Training, independent review and policy updates

Relevant personnel receive training appropriate to their responsibilities, including identification of unusual activity, escalation, confidentiality, sanctions, fraud, record keeping and the prohibition on tipping-off.

The control framework may be tested through quality assurance, compliance monitoring, audit or independent review. This policy is reviewed periodically and may be updated to reflect legal developments, risk assessments, new products, new technology or lessons from incidents and regulatory guidance.

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