AML & KYC policy

1. Purpose and scope

This policy describes how BDA identifies clients, assesses risk and decides whether to accept or continue an engagement. It applies to all clients, beneficial owners, directors and authorised representatives involved in a project.

Providers involved in a project (banks, registered agents, licensed institutions) apply their own AML/KYC procedures in addition to ours.

2. Customer due diligence

Before an engagement starts we collect, as relevant: a valid passport or national ID, proof of residential address, a short professional background, the ownership and control structure, and a description of the intended activity, countries and expected transactions.

For companies we also collect corporate documents, registers of directors and shareholders, and identification of every beneficial owner (normally anyone holding or controlling 25% or more, or exercising control by other means).

3. Source of funds and wealth

We ask for a reasonable explanation and supporting evidence of the source of funds used in the project and, where risk requires, of the client's overall wealth.

4. Sanctions, PEP and public-information checks

We screen clients, beneficial owners and relevant counterparties against applicable sanctions lists (including OFAC, UN, EU and UK lists) and check for politically exposed person status and relevant adverse public information.

5. Enhanced due diligence

Additional information and senior review apply to higher-risk cases, such as politically exposed persons, high-risk countries, complex or opaque structures, crypto-asset, gaming, payment or other regulated activities, and unusual transactions.

6. Refusal and termination

BDA does not accept or continue engagements where identity, ownership or source of funds cannot be established, where sanctions apply, or where we suspect money laundering, terrorist financing, fraud, tax evasion or other unlawful activity. We are not obliged to give reasons for a refusal.

7. Ongoing monitoring

For continuing engagements we keep client information up to date and review it when circumstances change or risk increases.

8. Record keeping

KYC records and engagement files are kept securely for at least five years after the end of the business relationship, or longer where law or a Provider requires it, and are shared only as described in our Privacy Policy.

9. Reporting and cooperation

Where required by law, BDA cooperates with competent authorities and may report suspicious activity without informing the client.

10. Client undertakings

Clients must provide true and complete information, inform us of changes in ownership, control or activity, and not use our services for any unlawful purpose.