AML & CFT Policy
Contents
- 1. Introduction & Legal Framework
- 2. Purpose
- 3. Identity Verification (KYC)
- 4. Beneficial Ownership (BO)
- 5. Customer Due Diligence (CDD)
- 6. AML Screening and Verification
- 7. Ongoing Monitoring
- 8. Deposits and Withdrawals
- 9. Record-Keeping
- 10. Staff Training & Compliance Oversight
- 11. Client Awareness & Cooperation
- 12. Disclosure & Legal Right to Actions
- 13. Data Protection
- 14. Availability of the Full Manual
- 15. Contact Information
- Annexure 1 Customer Due diligence Requirements
1. Introduction & Legal Framework
Caveo FX Limited (“the Company”) is incorporated under the laws of Seychelles and licensed as a Securities Dealer by the Financial Services Authority (FSA) under license number SD213.
This Policy has been prepared in accordance with the Anti-Money Laundering and Countering the Financing of Terrorism Act, 2020, the Anti-Money Laundering Regulations, the Beneficial Ownership Act, 2020, and other applicable laws and guidelines issued by the FSA. It demonstrates the Company’s commitment to preventing money laundering (ML) and terrorist financing (TF) and to protecting the integrity of the financial system.
2. Purpose
The purpose of this Policy is to provide clients with an overview of the measures taken by the Company to prevent its services from being misused for financial crime. It sets out the Company’s approach to client due diligence, ongoing monitoring, record-keeping, and reporting obligations in line with applicable legal requirements.
3. Identity Verification (KYC)
The company requires all clients to provide reliable, independent source documents to verify their identity before establishing a business relationship.
4. Beneficial Ownership (BO)
The company is required to identify and verify the identity of the ultimate Beneficial Owner (BO) of any business relationship/transaction it conducts with any legal person or arrangement.
5. Customer Due Diligence (CDD)
The Company applies a risk-based approach to Customer Due Diligence (CDD). This includes:
- Verifying the identity of clients before establishing and during the course of the business relationship.
- Obtaining information on the purpose and intended nature of the business relationship.
- Applying Enhanced Due Diligence (EDD) for higher-risk clients, such as politically exposed persons (PEPs) or clients from high-risk jurisdictions.
- Periodically reviewing and updating client information.
6. AML Screening and Verification
The company engages with third party AML/CFT screening service providers to continuously screen client’s personal profile and transactions in line with local regulations and international AML best practice.
7. Ongoing Monitoring
The Company conducts ongoing monitoring of transactions and account activity to ensure they are consistent with the client’s profile and source of funds. Particular attention is given to complex, unusual, or high-value transactions which may indicate a heightened risk of money laundering or terrorist financing.
In addition, the Company reviews the customer identity/profile during the course of the business relations to establish any changes in the client’s personal status that will impact the client’s risk profile. Consideration is given to (including, but not limited to), changes in geographical risk, Political Exposure (PEP), Sanction status, or adverse media findings.
Following the result of its ongoing monitoring the Company reserves the right to take other enforcement actions such as requesting enhanced customer due diligence documents, and apply other scrutiny which will allow it to comply with its regulatory requirement under the AML/CFT laws of Seychelles.
8. Deposits and Withdrawals
The Company only accepts deposits and processes withdrawals from accounts held in the client’s own name and accounts disclosed to the Company at the time of onboarding due diligence process. Third-party payments are not permitted unless fully justified and supported by additional due diligence. The Company may request evidence of the source of funds and reserves the right to delay or reject transactions that cannot be sufficiently verified.
9. Record-Keeping
The Company maintains accurate records of client identification documents, transaction history, and correspondence for at least seven (7) years after the end of the client relationship. These records may be made available to competent authorities upon request.
10. Staff Training & Compliance Oversight
All staff receive ongoing AML/CFT training to ensure awareness of legal obligations, risk indicators, and reporting procedures. The Company has appointed a qualified Compliance Officer with the authority and independence to oversee the AML/CFT framework and ensure ongoing compliance.
11. Client Awareness & Cooperation
Clients are expected to cooperate fully with the Company’s AML/CFT procedures. This includes providing accurate and up-to-date information, supporting documents, and promptly responding to any due diligence requests. Failure to provide the required information may result in delays, restrictions, or refusal of services.
12. Disclosure & Legal Right to Actions
The Company reserves the right to request additional information, refuse, suspend, or terminate any transaction or client relationship in line with its internal policies and AML/CFT obligations, where the risk is deemed unacceptable or where the client fails to satisfy CDD requirements. The Company may also make any disclosures or reports to the relevant authorities as required under applicable laws and regulations.
13. Data Protection
The client data collected for AML/CFT purposes will be handled and protected in line with applicable data protection laws.
14. Availability of the Full Manual
This document summarises the key principles of the Company’s AML/CFT framework. A detailed internal manual is maintained for regulatory purposes and oversight.
15. Contact Information
For questions about this Policy or the Company’s AML/CFT measures, please contact us at:
- Email: [email protected]
- Compliance Department: [email protected]
- Address: IMAD Complex, 3rd Floor, Office 12, Ile Du Port, Mahé, Seychelles
Annexure 1 Customer Due diligence Requirements
The Company has mandatory obligation to collect the below listed customer due diligence documents and the client shall comply to this customer due diligence to establish a successful business relationship with the Company.
Standard CDD procedures
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Natural Person:
Proof Identity should be verified via one of the following:
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Valid Passport;
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National ID Card;
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Current photo-card driving license.
The indicated documents should show a clear photograph of the customer, not reach the expiry date (if applicable), all sides of the document to be visible (not cropped) and all information available should be legible for our officer’s use.
- Date and Place of Birth
- Unique personal identification number
- Issuance and expiration date. Proof of current residential address will be verified by one of the following:
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A recent utility bill – mobile phone bills not acceptable;
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Bank statement;
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Credit card statement (monthly).
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Government issued document
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Lease agreement stating the residential address
The indicated document should not be older than 3 months from the filing date, legible and translated if not in English or French. P.O. Box Address not acceptable.
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Legal Entity
Verify the legal existence and structure of the entity using documents such as:
| Entity type | Document Type |
|---|---|
| Company | Certificate of Incorporation Certificate of Regulatory Approvals (if applicable) Recent (up to 6 months) certificate of good standing. Memorandum And Articles of Association Register of Directors – standard identification document listed as per point (i) above for each natural person director or standard identification listed here for each corporate director Register of Members - standard identification document listed as per point (i) above for each natural person shareholder/beneficial owner with 10% or more ownership interest/ any other natural person exercising effective control over the company. standard identification listed here for each corporate shareholder, Audited financial statements for the last ensuing financial year end |
| Trust | Registration Document Certificate of Regulatory Approvals (if applicable) Trust Deed List of Trustees and Beneficiaries standard identification document listed as per point (i) above for each natural person Trustee and beneficiary with 10% or more ownership interest/ any other natural person exercising effective control over the trust. standard identification listed here for each corporate Trustee and beneficiary Audited financial statements for the last ensuing financial year end |
| Partnership | Registration Document Certificate of Regulatory Approvals (if applicable) Partnership agreement standard identification document listed as per point (i) above for each natural person partner or standard identification listed here for each corporate partner Audited financial statements for the last ensuing financial year end |
Enhanced Due Diligence (EDD):
For clients identified as high-risk, perform EDD measures, which may include:
- Obtaining additional information about the client’s source of funds and wealth
- Conducting more thorough background checks and requesting additional identification documents
- Proof of source of Fund (to be provided upon request), the list includes but not limited to:
- Income from business/Capital of Company – Audited financial Statements for last financial year
- Dividends - Brokerage/Investment Account Statement or Dividend Vouchers/Contract Notes with the Bank statement showing the proceeds deposited to your account
- Inheritance - Copy of the Will and/or Grant of Probate or Letter of Administration along with Bank statement showing the inherited funds being received
- Professional Salary – pay slip for past 3-6 months
- Gift - A Signed Gift Letter or Affidavit from the donor confirming the gift is non-repayable along with ID and Proof of Address for the donor and source of funds of donor.
- Savings – Bank Statements for the past 6months-1year
- Profit from sold or mature investment - Investment Account Statement or portfolio valuation showing the sale with the Bank statement showing the proceeds deposited to your account.
- Profit from property sale – Property Sale Agreement and bank statement showing the deposit of the funds
- Profit from Company sale – Contract/Sale Agreement and bank statement showing deposits of the funds
- Regular Income from owned property rental – title deeds and copy of lease agreement(s) or rental receipts for the last three months
- Compensation Payment – Letter issued by employer detailing the compensation paid and the bank statement showing the deposit of the funds
- Pension - Official statements from the pension administrator, scheme manager, or insurance company clearly showing, the gross and net amounts, and the payment schedule or a recent letter from the provider confirming the amount, start date, and scheme details may be requested or A formal document from the pension provider confirming the total amount of the lump sum paid out and the date of payment for large lump sum payment of pension.