AML / KYC Policy

1. Introduction

Pinakine Liquidity is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines our procedures and requirements for client identification, verification, and ongoing monitoring.

We operate in accordance with international AML standards and applicable regulations in the jurisdictions where we provide services. All clients are required to comply with our AML/KYC requirements as a condition of using our services.

2. Legal Framework

Our AML/KYC procedures are based on:

• International standards set by the Financial Action Task Force (FATF)
• Applicable laws and regulations in Saint Lucia
• Best practices in the financial services industry
• Regulatory guidance from relevant authorities

We regularly review and update our policies to ensure compliance with evolving regulatory requirements.

3. Know Your Customer (KYC) Requirements

3.1 Initial Verification

Before opening an account, all clients must provide:

• Identity Verification:
  • Valid government-issued photo ID (passport, national ID card, or driver's license)
  • Full name as it appears on official documents
  • Date of birth
  • Nationality
• Address Verification:
  • Proof of residential address (utility bill, bank statement, or government-issued document)
  • Document must be dated within the last 3 months
  • Address must match the address provided during registration
• Contact Information:
  • Valid email address
  • Active phone number
  • Mailing address

3.2 Enhanced Due Diligence (EDD)

Enhanced verification may be required for:

• High-value transactions or deposits
• Politically Exposed Persons (PEPs)
• Clients from high-risk jurisdictions
• Complex or unusual transaction patterns
• Corporate or institutional accounts

Enhanced due diligence may include additional documentation such as proof of income, source of funds, beneficial ownership information, and professional references.

4. Source of Funds Verification

We are required to verify the source of funds deposited into trading accounts. Clients may be asked to provide:

• Bank statements showing the origin of funds
• Salary slips or employment contracts
• Tax returns or financial statements
• Documentation for business income or investments
• Gift declarations or inheritance documents
• Any other documentation that demonstrates the legitimate origin of funds

We reserve the right to request additional information at any time to verify the source of funds, especially for large deposits or unusual transactions.

5. Ongoing Monitoring and Transaction Monitoring

5.1 Transaction Monitoring

We continuously monitor client accounts and transactions for:

• Unusual or suspicious transaction patterns
• Transactions inconsistent with client profile
• Large or frequent deposits and withdrawals
• Transactions with high-risk jurisdictions
• Structured transactions designed to avoid reporting thresholds

5.2 Account Review

We conduct periodic reviews of client accounts to:

• Verify that client information remains current
• Assess changes in risk profile
• Update documentation as required
• Ensure compliance with ongoing obligations

6. Suspicious Activity Reporting

We are legally obligated to report suspicious activities to relevant authorities. Suspicious activities may include:

• Transactions inconsistent with client's known business or personal activities
• Unusual patterns of deposits or withdrawals
• Attempts to avoid reporting or record-keeping requirements
• Transactions involving known or suspected criminals or terrorist organizations
• Complex or unusual transactions with no apparent economic purpose
• Use of false or stolen identity documents

When we identify suspicious activity, we will:

• Conduct additional investigation
• File a Suspicious Activity Report (SAR) with relevant authorities
• Take appropriate action, which may include account suspension or closure
• Cooperate with law enforcement and regulatory investigations

7. Sanctions and Watchlist Screening

We screen all clients against international sanctions lists and watchlists, including:

• United Nations sanctions lists
• Office of Foreign Assets Control (OFAC) sanctions
• European Union sanctions
• Other relevant international sanctions regimes
• Politically Exposed Persons (PEP) databases

We will not open accounts or process transactions for individuals or entities on sanctions lists. If a client is identified as a sanctioned party, we will immediately freeze the account and report to relevant authorities.

8. Record Keeping

We maintain comprehensive records of:

• Client identification and verification documents
• Account opening forms and agreements
• Transaction records and history
• Source of funds documentation
• Correspondence and communications with clients
• Suspicious activity reports and investigations

Records are retained for a minimum period as required by applicable laws and regulations, typically 5-7 years after account closure or the last transaction.

9. Client Cooperation Requirements

Clients are required to:

• Provide accurate and complete information during account opening
• Submit all requested verification documents promptly
• Update their information when it changes (address, contact details, etc.)
• Respond to requests for additional information or documentation
• Cooperate with ongoing monitoring and review processes
• Report any changes in circumstances that may affect their risk profile

Failure to comply with AML/KYC requirements may result in account restrictions, suspension, or closure.

10. Staff Training and Compliance

We ensure that all staff members receive regular training on:

• AML/KYC policies and procedures
• Identification of suspicious activities
• Regulatory requirements and updates
• Client due diligence best practices
• Reporting obligations

Our compliance team regularly reviews and updates our AML/KYC procedures to ensure effectiveness and regulatory compliance.

11. Privacy and Confidentiality

While we are required to collect and verify personal information for AML/KYC purposes, we are committed to:

• Protecting the confidentiality of client information
• Using information only for legitimate compliance purposes
• Sharing information only as required by law or with authorized parties
• Maintaining secure storage and transmission of sensitive data

For more information about how we handle personal information, please refer to our Privacy Policy.

12. Contact Information

For questions about our AML/KYC requirements or to submit verification documents, please contact us:

• Email: Support@pinakineliquidity.com
• Phone: +447454630174
• Address: Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia

Compliance Department: For compliance-related inquiries, please email us with "AML/KYC Compliance" in the subject line.