AML/KYC Policy

Company formation and administrative services can be misused to hide who really owns a business. Because of that, we identify our customers and the people who ultimately own or control them before we act, and we keep those records.

This is not optional and it is not a formality. If we cannot establish who is behind a business, we do not act for it.

• Identity of each director, shareholder, partner and authorised signatory.
• Address, with supporting evidence.
• Beneficial ownership: the natural people who ultimately own or control the business, including through a corporate or trust shareholder.
• Politically exposed person status.
• Sanctions and adverse-media screening.
• Source of funds and, where the risk requires it, source of wealth.
• The intended business activity and the purpose of the arrangement.

Each of these is tracked as its own status in the case, so you can see what is outstanding.

Cases are rated for risk and the depth of the checks follows the rating. Enhanced review applies where there is foreign ownership, a corporate or trust shareholder, a nominee arrangement, a regulated sector, a politically exposed person, or funding we cannot explain from the information given.

A risk rating is recorded with the reason for it and who decided it.

Every compliance decision is made by a named person, with a recorded reason, and it is not something the software decides on its own. Screening tools assist a reviewer; they never approve or reject a case automatically.

Where we are required to make a report, we do so. We may be legally prohibited from telling you that a report has been made or is being considered. If that applies, we will say only that we are unable to proceed.

*This document describes the controls the platform is built to support. It is a draft and must be reviewed, completed and approved by a qualified Bangladesh AML compliance professional before launch, including the appointment of a compliance officer, the reporting thresholds, the record-retention period and the internal escalation procedure. Software alone does not make an organisation compliant.*