Anti-Money-Laundering Policy

1. Purpose and scope

This policy sets out how SiaFundy prevents its services being used for money laundering, terrorist financing or sanctions evasion. It applies to all staff, contractors and every client relationship without exception.

It is designed around the UK Money Laundering Regulations and FCA expectations for cryptoasset businesses. Our FCA registration application is in progress.

2. Governance

A nominated officer holds responsibility for the AML programme, receives internal suspicion reports and decides whether to escalate them externally. Senior management reviews the programme and its risk assessment at least annually.

3. Risk assessment

We maintain a written business-wide risk assessment covering client type, geography, product, delivery channel and transaction pattern. Each client is scored at onboarding and re-scored when their profile or behaviour changes.

4. Customer due diligence

We do not open accounts anonymously and we do not accept nominee arrangements that obscure the beneficial owner.

• Standard due diligence: verification of legal name, date of birth and residential address against independent sources, plus a government-issued identity document.
• Source of funds and source of wealth review proportionate to the risk score and the values involved.
• Enhanced due diligence for politically exposed persons, high-risk third countries, unusual transaction patterns and any client we cannot verify by standard means.
• Ongoing due diligence: periodic refresh of client records, with frequency driven by risk rating.

5. Screening

All clients are screened at onboarding and on an ongoing basis against consolidated sanctions lists, politically-exposed-person registers and adverse media. Positive matches are escalated to the nominated officer before any relationship proceeds.

6. Transaction monitoring

Deposits, withdrawals, swaps and on-chain movements are monitored against risk rules covering value thresholds, velocity, counterparty exposure and structuring patterns.

Where blockchain analytics indicate exposure to sanctioned addresses, darknet markets, mixers or known theft clusters, the transaction is held pending compliance review.

7. Reporting suspicious activity

Staff must report any suspicion internally to the nominated officer immediately, without investigating further themselves. The nominated officer decides whether a report to the relevant financial intelligence unit is required.

Tipping off a client that a report has been made or is being considered is a criminal offence and is strictly prohibited.

8. Record keeping

Due diligence records, screening results, transaction data and internal suspicion reports are retained for at least five years after the end of the relationship or the completion of the transaction, whichever is later. Staff actions are recorded in an append-only audit log.

9. Training

All staff receive AML and financial-crime training at induction and at least annually thereafter, with additional targeted training for compliance and investigation roles.

10. Non-compliance

Breach of this policy is a disciplinary matter and may amount to a criminal offence. Clients who provide false information or attempt to misuse the platform will have their accounts suspended and, where appropriate, reported.

Contact: support@siafundy.com.