AML/KYC Policy

1. Purpose

Integrox operates a risk-based anti-money laundering and counter-terrorist financing programme. Its purpose is to prevent our services being used to launder the proceeds of crime or to finance terrorism, and to meet our obligations under applicable AML legislation.

2. Governance

A Money Laundering Reporting Officer (MLRO) owns the programme, approves escalations and is responsible for reporting suspicious activity to the relevant financial intelligence unit. Staff receive AML training on appointment and annually.

3. Customer due diligence

• Identification and verification of the client's identity before the engagement starts.
• Verification of business clients' ownership and control structure where applicable.
• Understanding the purpose and intended nature of the engagement.
• Enhanced due diligence for higher-risk clients, jurisdictions or transaction values.

4. Screening

With client consent, client details are screened against sanctions lists, politically exposed person data and adverse media using a licensed screening provider. Screening is performed server-side by that provider; no screening decision is made in the client's browser and no outcome is simulated or self-certified by Integrox.

5. Ongoing monitoring

Client records are reviewed periodically and on trigger events such as a change of circumstances or an unusual instruction.

6. Suspicious activity

Where we know or suspect money laundering, we file a report with the relevant authority. We may be prohibited by law from informing the client that a report has been made ("tipping off"), and we may be unable to explain the reason for a declined or suspended engagement.

7. Record keeping

Due diligence records, screening results and decision notes are retained for the statutory period and every status change is timestamped in an immutable audit trail.

8. Not a banking service

Our checks are performed for our own regulatory purposes as a consultancy. They are not performed on behalf of any bank and do not constitute, imply or guarantee approval of any bank account, loan, credit facility, visa or licence by any third party.