Compliance

Anti-Money Laundering Policy

NothingHolders Ltd is committed to preventing the use of its platform for money laundering, terrorist financing, and other financial crimes.

1. Our Commitment

NothingHolders Ltd is fully committed to compliance with applicable anti-money laundering (AML) and counter-terrorist financing (CTF) legislation and regulations. We operate a robust AML programme designed to detect, prevent, and report suspicious activity.

2. Legal Framework

Our AML programme is designed to comply with applicable AML/CTF legislation and regulations in our jurisdiction of operation, including EU directives on money laundering prevention where applicable, Financial Action Task Force (FATF) recommendations, and local legislation as applicable.

3. Customer Due Diligence (CDD)

We conduct Customer Due Diligence (CDD) on all clients before providing services. This includes:

  • Identity verification using government-issued photo identification
  • Proof of address verification (utility bill, bank statement)
  • Assessment of the source of funds and source of wealth
  • Screening against sanctions lists, politically exposed persons (PEP) lists, and adverse media

Enhanced Due Diligence (EDD) is applied to higher-risk clients, including PEPs, clients from higher-risk jurisdictions, and large-value transactions.

4. Ongoing Monitoring

Client activity and transactions are monitored on an ongoing basis to detect unusual or suspicious patterns. Monitoring includes transaction thresholds, geographic risk factors, behavioural anomalies, and inconsistencies with the stated source of funds.

5. Suspicious Activity Reporting

Where suspicious activity is identified, we are legally obligated to file a Suspicious Activity Report (SAR) with the relevant financial intelligence unit. We are legally prohibited from informing the client that such a report has been made ("tipping off" prohibition).

6. Prohibited Activities

The following activities are strictly prohibited and will result in immediate account suspension and reporting to authorities:

  • Depositing funds from third-party accounts not in the client's name
  • Using the platform to layer or integrate proceeds of criminal activity
  • Providing false or misleading information during the account opening or verification process
  • Circumventing AML controls through structuring transactions
  • Operating the account on behalf of an undisclosed third party

7. Record Keeping

All client identity documents, transaction records, and AML-related documentation are retained for a minimum of 5 years (or longer as required by law) in accordance with regulatory requirements.

8. Staff Training

All relevant staff receive regular AML training and are aware of their obligations to report suspicious activity. A designated Money Laundering Reporting Officer (MLRO) oversees the AML programme.

9. Sanctions Compliance

We comply with all applicable international sanctions and embargoes. We screen all clients against EU, UN, OFAC, and other applicable sanctions lists. Individuals or entities on sanctions lists cannot open or maintain accounts.

Last updated: January 2024.