Chrysanthou Mylona 1-3030, Panaghides Building, Episkopi, Cyprus, 350
Room 2a 14/f Chun Wo Commercial Centre, 23–29 Wing Wo Street, Central, Hong Kong
1.1. This Anti-Money Laundering and Counter-Terrorist Financing Policy (hereinafter referred to as the “Policy”) establishes the principles and procedures applied by Veritas Advisory Group Limited (hereinafter referred to as the “Company”) to prevent the use of its services for money laundering, terrorist financing, and other unlawful activities. This AML Policy, including all terms and provisions, has been individually developed taking into account the Company’s business activities, internal rules, and operational model. The document has been prepared with the involvement of qualified professionals (including legal and audit specialists) and reflects the actual processes applied by the Company in its interaction with website visitors and clients.
1.2. The purpose of this Policy is to ensure compliance with applicable regulatory requirements and to protect the Company from legal, financial, and reputational risks.
1.3. The Company applies a zero-tolerance approach to illegal activities.
2.1. This Policy applies to all employees, consultants, contractors, and partners of the Company.
2.2. The Policy applies to all clients, transactions, and projects at all stages of engagement.
3.1. The Company operates in accordance with applicable AML/CTF requirements, including:
3.1.1. European Union Anti-Money Laundering Directives (AMLD);
3.1.2. national legislation of applicable jurisdictions;
3.1.3. FATF recommendations and other international standards.
4.1. The Company applies a risk-based approach when assessing clients and transactions.
4.2. The assessment takes into account:
4.2.1. client jurisdiction;
4.2.2. client type (individual or legal entity);
4.2.3. ownership structure;
4.2.4. nature of the transaction;
4.2.5. other risk factors.
4.3. The extent of due diligence depends on the level of risk.
5.1. Prior to establishing a business relationship, the Company conducts client identification (KYC).
5.2. Due diligence includes:
5.2.1. identification of the client;
5.2.2. verification of ultimate beneficial owners (UBO);
5.2.3. understanding the purpose and nature of the relationship.
5.3. Due diligence may be updated during the course of the relationship.
6.1. Enhanced due diligence measures are applied in higher-risk cases.
6.2. Such cases include:
6.2.1. complex corporate structures;
6.2.2. offshore jurisdictions;
6.2.3. large or unusual transactions;
6.2.4. politically exposed persons (PEPs).
6.3. Additional documentation and source of funds analysis may be required.
7.1. The Company may require verification of Source of Funds and Source of Wealth.
7.2. Where the lawful origin of funds cannot be confirmed, the Company reserves the right to refuse engagement.
8.1. The Company conducts ongoing monitoring of client relationships throughout the engagement.
8.2. Monitoring includes:
8.2.1. transaction analysis;
8.2.2. tracking changes in risk profile;
8.2.3. updating client information.
9.1. The Company applies procedures for detecting suspicious activity.
9.2. In case of suspicion:
9.2.1. an internal investigation is conducted;
9.2.2. the matter is escalated to the responsible officer;
9.2.3. where required, a report is submitted to competent authorities.
9.3. The client may not be notified of such actions where prohibited by law.
10.1. The Company conducts sanctions screening.
10.2. The Company does not enter into relationships with sanctioned persons or those associated with them.
10.3. Where sanctions risks are identified, the relationship is terminated.
11.1. The Company reserves the right to refuse or terminate cooperation in the following cases:
11.1.1. inability to identify the client;
11.1.2. failure to provide required information;
11.1.3. suspicion of unlawful activity;
11.1.4. presence of unacceptable risks.
12.1. The Company maintains:
12.1.1. client identification data;
12.1.2. due diligence documentation;
12.1.3. transaction records.
12.2. Retention periods are determined in accordance with applicable legislation.
12.3. Upon achievement of processing purposes or where processing is no longer necessary, data shall be deleted, destroyed, or anonymized, unless further retention is required by law.
12.4. Data may be provided to competent authorities where required.
13.1. Data processing is carried out in accordance with applicable legislation, including GDPR.
13.2. Access to data is restricted to authorized persons.
13.3. Appropriate measures are implemented to prevent unauthorized access.
14.1. Staff are required to comply with this Policy.
14.2. Staff obligations include:
14.2.1. conducting due diligence;
14.2.2. identifying risks;
14.2.3. reporting suspicious activity.
14.3. Breach of this Policy may result in disciplinary and legal consequences.
15.1. The Company provides regular training to staff.
15.2. Training covers current risks, legislation, and AML practices.
16.1. The Company maintains a compliance function.
16.2. A designated Compliance Officer is appointed, who:
16.2.1. oversees compliance with this Policy;
16.2.2. manages risks;
16.2.3. liaises with regulatory authorities.
17.1. Violations of this Policy are addressed in accordance with internal procedures.
17.2. Where necessary, information may be reported to competent authorities.
18.1. The Company reserves the right to amend this Policy.
18.2. Amendments become effective upon publication.
19.1. For AML and compliance-related inquiries, the Company may be contacted at: info@veritas-advisory-group.com
