Anti-Money Laundering & Know Your Customer Policy

Polinvest is committed to the prevention of money laundering, terrorist financing, and all other forms of financial crime. This policy sets out our approach to AML/KYC compliance and applies to all clients, counterparties, investors, and service providers who engage with Polinvest in any capacity.

1. Our Commitment

We will not knowingly facilitate transactions that involve the proceeds of crime, support terrorist activity, or circumvent applicable sanctions. We take our obligations under applicable AML/CFT legislation seriously and have invested in the people, systems, and processes required to meet those obligations effectively. Senior management is responsible for the implementation of this policy and for ensuring that all staff are trained on their obligations.

2. Know Your Customer (KYC)

Before entering into any material business relationship with a new client, whether a borrower, investor, lender, or service provider, we conduct a thorough KYC assessment. This assessment involves verification of identity using official government-issued documents; verification of address using utility bills, bank statements, or equivalent; identification and verification of beneficial owners (individuals who ultimately own or control more than 25% of a legal entity); assessment of source of funds and source of wealth where relevant to the nature of the relationship; and screening against applicable sanctions lists and databases of politically exposed persons.

For corporate clients, KYC documentation requirements include corporate registration certificates, constitutional documents, shareholder registers, director identification, and audited financial statements. The specific documentation required varies depending on the client type, jurisdiction, and the nature of the proposed transaction.

3. Risk-Based Approach

We apply a risk-based approach to AML/KYC, allocating enhanced due diligence resources to relationships and transactions that present higher levels of risk. Higher-risk indicators include clients in high-risk jurisdictions as defined by the Financial Action Task Force (FATF); clients who are politically exposed persons (PEPs) or are connected to PEPs; transactions with complex or unusual structures that lack clear economic rationale; and relationships where the proposed transaction is inconsistent with the client's declared business or investment profile.

4. Ongoing Monitoring

Our AML/KYC obligations do not end at onboarding. We conduct ongoing monitoring of active client relationships to detect transactions or behaviours that are inconsistent with the established profile of the client or that otherwise raise suspicion. Client profiles are reviewed at least annually and are updated when material changes in the client's circumstances are brought to our attention. Unusual transaction activity is escalated internally for review by our compliance function.

5. Sanctions Compliance

We screen all clients, counterparties, and transactions against applicable sanctions lists including those maintained by the United Nations, the European Union, the United Kingdom, the United States Office of Foreign Assets Control (OFAC), and other relevant authorities. We will not facilitate any transaction that would violate applicable sanctions, and we terminate existing relationships where sanctions designations are imposed on existing clients or counterparties.

6. Suspicious Activity Reporting

Where our compliance function identifies a transaction or relationship that gives rise to a suspicion of money laundering, terrorist financing, or sanctions evasion, we will make a report to the relevant financial intelligence unit as required by applicable law. We do not "tip off" clients that a suspicious activity report has been or may be made, in accordance with applicable legal requirements.

7. Staff Training

All Polinvest staff receive AML/KYC training appropriate to their role on joining the firm and on a regular basis thereafter. Staff are required to complete annual AML refresher training and to certify their understanding of our obligations. Our compliance function maintains records of all training completed.

8. Record Keeping

We maintain records of all KYC documentation, transaction records, and AML monitoring activities for a minimum of five years from the date of the relevant transaction or the end of the relevant business relationship, whichever is later. Records are stored securely and are accessible to regulators and law enforcement agencies upon lawful request.

9. Reporting Concerns

If you have reason to believe that a transaction or relationship involving Polinvest may involve money laundering, terrorist financing, or sanctions evasion, please report your concerns to our compliance team immediately via the contact page. All reports will be treated as strictly confidential.