AML and Counter-Terrorist Financing Policy

Introduction

The AML and Counter-Terrorist Financing (CTF) Policy of SuisseBase™ is crafted to uphold rigorous standards in compliance with Swiss and European directives aimed at combating money laundering and terrorist financing. This policy mandates the establishment of robust systems and controls to mitigate the risk of our platform being exploited for illicit financial activities.

Engaging in any form of business activity or process transactions that benefit individuals or entities listed on international sanctions registers is strictly prohibited. Therefore, adherence to all relevant laws and regulations pertaining to the prevention of money laundering and terrorist financing, particularly the Swiss Anti-Money Laundering Act (referred to as "AML"), is integral to the strategic framework and operational ethos of SuisseBase™.

SuisseBase™ maintains stringent and transparent criteria, continually enhancing its operational procedures to ensure full compliance with applicable AML laws and regulations. We reserve the right to decline any customer, payment, or business endeavor that contravenes the principles outlined in our AML policy, irrespective of the requirements stipulated by prevailing AML laws and regulations.

This commitment underscores our dedication to maintaining the highest integrity and regulatory compliance standards across all facets of our operations.

Core Objectives

Our primary objectives at SuisseBase™ encompass:

  • Vigilantly combating and thwarting money laundering and terrorist financing activities, bolstered by robust preventive measures.

  • Safeguarding the integrity of our operations from any misuse by individuals engaging in illegitimate activities.

  • Appointment of a senior and autonomous Money Laundering Reporting Officer (MLRO) tasked with ensuring compliance with relevant legislation, regulations, and industry directives.

  • Implementation and upkeep of a Risk-Based Approach (RBA) to effectively assess and manage the firm's exposure to money laundering and terrorist financing risks.

  • Adoption of risk-based Customer Due Diligence (CDD), encompassing thorough identification, verification, and Know Your Customer (KYC) procedures, with heightened scrutiny for high-risk clients such as Politically Exposed Persons (PEPs).

  • Deployment of tailored systems and protocols for continuous monitoring of customer activities aligned with risk profiles.

  • Establishment of comprehensive procedures for internally reporting suspicious activities and liaising with pertinent law enforcement entities, including the Money Laundering Reporting Office Switzerland (MROS), as necessitated.

  • Maintenance of meticulous records in accordance with regulatory mandates.

  • Provision of comprehensive training to all staff on pertinent rules, internal procedures, and the specific money laundering and terrorist financing risks inherent to their roles within the company.

These core objectives underscore SuisseBase™'s commitment to robust AML/CFT practices, ensuring compliance with regulatory frameworks and bolstering our defenses against financial crime threats.

Commitment

At SuisseBase™, our commitment is focused on the following principles:

  • We only onboard customers after thoroughly verifying their identity and ensuring the legitimacy of their funding sources.

  • We do not establish business relationships, open accounts, or maintain accounts for anonymous individuals or those using fictitious identities, including anonymous accounts.

  • Every effort is made to ascertain the identity of the customer and the ultimate beneficiary (Beneficial Owner) of the account, verifying details such as full name, place of birth, and date of birth using valid, official documents issued by recognized authorities, alongside information from credible independent sources.

  • We employ a risk-based approach, implementing enhanced due diligence as necessary to manage risks effectively.

  • Our systems diligently monitor and flag suspicious transactions and activities for appropriate reporting.

  • Regular and comprehensive AML/CTF training is provided to all employees through diverse educational methods to enhance awareness.

  • We maintain meticulous records tailored to the specific nature and complexity of each customer's business activities.

These commitments underscore SuisseBase™'s dedication to robust AML and CTF practices, ensuring compliance with regulatory standards and safeguarding our operations against financial crime risks.

Customer Due Diligence

SuisseBase™ is committed to fulfilling its legal obligations by thoroughly identifying and verifying applicants for business, customers, and beneficial owners. It is imperative to establish the true identity of individuals and ascertain if they are acting on behalf of others. This process includes determining the purpose and intended nature of the business relationship, which is continuously monitored.

Our Customer Due Diligence (CDD) measures are meticulously designed and implemented across all levels of our organization. These measures assist in assessing each customer's risk profile and provide insights into their business activities. Any transactions that deviate from the expected business profile undergo thorough scrutiny to detect potential money laundering or terrorism financing activities. Prompt reporting to relevant authorities is ensured whenever necessary information is identified.

In essence, SuisseBase™'s Due Diligence policies are structured to achieve the following objectives:

  • Verification and identification of applicants for business.

  • Identification and verification of beneficial owners, where applicable.

  • Verify that individuals are not acting as principals in their applications.

  • Gathering comprehensive information on the purpose and nature of business relationships.

  • Continuous monitoring of business relationships.

  • Establishment of the source of wealth and funds.

  • Implementation and enforcement of a robust Customer Acceptance Policy to uphold compliance standards.

SuisseBase™ strictly prohibits the maintenance of anonymous or fictitious accounts to uphold transparency and regulatory compliance.

These measures underscore our commitment to maintaining the highest integrity and regulatory compliance standards in all our operations.

Prohibited Activities

SuisseBase™ maintains a stringent stance against engaging with customers involved in activities that pose significant risks under AML and CTF regulations:

  • Deliberate or negligent violations of laws, regulations, or policies pertaining to money laundering and terrorist financing.

  • Repeated accidental breaches of AML laws.

  • Misuse of accounts for purposes of money laundering, terrorism financing, or other fraudulent activities.

  • Participation in activities that could be construed as tax evasion.

  • Failure to provide adequate information or documentation to demonstrate compliance with SuisseBase™'s AML policies.

Moreover, SuisseBase™ refrains from conducting business with customers or transactions originating from jurisdictions identified as high-risk third countries. These jurisdictions are identified based on deficiencies in their anti-money laundering frameworks as outlined by the European Commission and the FATF.

Compliance with Sanctions

SuisseBase™ adheres strictly to regulatory sanctions, avoiding the establishment or maintenance of relationships with natural persons or legal entities designated on the following sanctions lists:

  • Swiss Federal Council Sanctions List.

  • United Nations Security Council Sanctions List (UN).

  • Consolidated List of European Union Financial Sanctions (EU).

  • Sanctions administered by the United States Office of Foreign Assets Control (OFAC), including the List of Specially Designated Nationals and Blocked Persons.

Additionally, SuisseBase™ exercises heightened vigilance concerning entities from countries listed as noncooperative by the Financial Action Task Force (FATF), ensuring stringent adherence to regulations governing monetary operations involving such entities.

These measures underscore SuisseBase™'s commitment to robust AML and CTF compliance, safeguarding against financial crime and preserving the integrity of our operations.

Monitoring for Suspicious Activity

SuisseBase™'s AML policy encompasses rigorous due diligence on customers and beneficial owners, complemented by ongoing monitoring and reporting protocols. Periodically, we may require detailed information on transactions conducted through our customers' accounts and the involved parties. Should a customer fail to provide adequate or timely responses to these requests, SuisseBase™ retains the right to decline associated payments in accordance with the mandates of applicable AML laws and regulations.

This proactive approach ensures that SuisseBase™ remains vigilant against potential risks of money laundering and illicit financial activities, reinforcing our commitment to upholding regulatory compliance and safeguarding the integrity of our operations.