AML, CTF & KYC Statement
The Registry's approach to anti-money laundering, counter-terrorist financing and know-your-customer controls, aligned with the FATF Recommendations and the laws of each jurisdiction in which it operates.
1. Statement
Eurabelt Fuels Ltd is committed to preventing the Registry from being used to launder the proceeds of crime or to finance terrorism or proliferation. Its controls follow the risk-based approach of the FATF Recommendations. They are designed with regard to:
- the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and the Proceeds of Crime Act 2002 (United Kingdom);
- the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada);
- the Financial Intelligence Centre Act 38 of 2001 (South Africa);
- the Proceeds of Crime Act, the Anti-Terrorism Act and the Financial Obligations Regulations (Trinidad and Tobago).
2. Customer due diligence
Every applicant undergoes the verification described in the Verification Standard:
- identification and verification of the entity, and of individual principals;
- identification of beneficial owners and of anyone exercising control;
- verification of the authority of the persons acting;
- an understanding of the nature of the business and the stated role in the fuel supply chain.
3. Enhanced due diligence
Enhanced measures apply to higher-risk situations, including:
- links to high-risk third countries or enhanced-review jurisdictions;
- politically exposed persons and their family members and close associates;
- complex or opaque ownership structures;
- activities with a heightened risk of trade-based money laundering, such as unusual routing, pricing or documentation.
Enhanced measures may include source-of-funds or source-of-product enquiries and senior compliance approval.
4. Ongoing monitoring
Active holders are monitored through periodic re-verification, continuous sanctions screening, review of verification patterns and notifications of change. Suspicious patterns trigger review, suspension of the code where appropriate, and reporting.
5. Reporting
Where the Registry knows or suspects money laundering or terrorist financing, it reports to the competent financial intelligence unit or authority in line with local law, and does not tip off the subject.
6. Record-keeping
Due-diligence and transaction-related records are retained as set out in the Data Retention Schedule.
7. Training and governance
Registry staff complete AML, CTF and sanctions training on joining and every year after that. A designated compliance lead is accountable for these controls and reports on them to the board.