AML, KYC and Sanctions Policy

bdoor supports lawful business formation and compliance. It does not assist anonymous ownership, sanctions evasion, money laundering, terrorist financing, proliferation financing, bribery, tax evasion, fraud or concealment of criminal proceeds.

Bangladesh law identifies trust and company service providers, lawyers, notaries, other legal professionals and accountants among reporting organisations and designated non-financial businesses and professions. bdoor must obtain a formal Bangladesh legal opinion on its exact classification and reporting duties before paid company-service operations begin. This Policy does not itself claim that bdoor has completed registration with, or received approval from, BFIU.

The free initial application should collect only the minimum non-sensitive information needed for routing and assessment. Identity documents and detailed source-of-funds evidence may be requested only after:

• the legal launch gate is approved;
• the customer receives a clear collection notice;
• an authorised secure upload route is available; and
• the requested data is necessary for the proposed engagement.

Depending on risk and jurisdiction, bdoor or the appointed regulated provider may verify:

• full legal name, date of birth, nationality and residential address;
• government-issued identity document and likeness;
• authority to act for another person or entity;
• proposed business activity and expected countries of operation;
• directors, shareholders, partners and beneficial owners;
• ownership and control structure;
• source of funds and, where proportionate, source of wealth;
• tax residence and relevant identification numbers;
• sanctions, adverse information and politically exposed person status; and
• the purpose and expected nature of the business relationship.

Information must be refreshed when circumstances change or the risk requires it.

Additional review may be required for complex or unusual structures, high-risk jurisdictions, politically exposed persons, sanctioned-country exposure, cash-intensive or regulated activity, nominee arrangements, inconsistent documents, unexplained third-party payments, adverse information or unusually urgent instructions.

Enhanced review may include independent evidence of wealth or funds, corporate-chain documents, translations, video verification, professional references, local legal advice, senior approval or refusal of the matter.

Screening must use the lists and legal restrictions applicable to bdoor, the customer, payment provider, appointed professional and requested jurisdiction. This may include United Nations and Bangladesh domestic sanctions and locally required lists. A possible match must be reviewed by an authorised person; an unreviewed software match must not be treated as proof.

bdoor will monitor relevant customer and case information for material inconsistencies or suspicious activity. Where bdoor or an appointed provider has a legal reporting obligation, a report may be made to the competent authority without customer consent and without notice where notice is prohibited. Only a properly authorised compliance person may decide or submit a report on bdoor’s behalf.

bdoor may decline, suspend or terminate a relationship where required information is unavailable, risk cannot be adequately managed, instructions may be unlawful, a sanctions restriction applies or a provider cannot accept the matter. bdoor is not required to disclose confidential risk rules or information whose disclosure would be unlawful.

Due-diligence and case records will be kept for the legally required period under the approved retention schedule, protected with restricted access and disclosed only for an authorised purpose. Staff and providers must not discuss suspicious-activity reviews outside authorised channels.

Before launch, bdoor must appoint an accountable AML/compliance lead, approve a business-wide risk assessment, document customer-risk scoring, train relevant staff, define escalation and reporting procedures, test the controls and maintain a current sanctions source list. Public wording must never imply BFIU endorsement.

Questions may be sent to hello@bdoor.io with the subject “Compliance”.