Elaris Corporate Services

AML & KYC Policy

Effective Date: 6 October 2026

This policy statement is published for the information of clients, prospective clients, and counterparties. It sets out the standards and obligations that govern Elaris Corporate Services’ approach to anti-money laundering, counter-terrorism financing, and customer due diligence.

1. Our Commitment

Elaris Corporate Services (“Elaris”) is committed to the highest standards of anti-money laundering (AML) and counter-terrorism financing (CTF) compliance. We recognise that corporate services providers occupy a position of particular responsibility in the global financial system, and we take that responsibility seriously.

We operate a zero-tolerance policy towards money laundering, terrorist financing, sanctions violations, tax evasion, and any other activity designed to conceal or disguise the true nature of funds or assets. We will not knowingly facilitate any such activity and will take all reasonable steps to prevent our services from being used for unlawful purposes.

2. Regulatory Framework

Our AML and KYC framework is designed to comply with applicable legislation and international standards, including:

  • The Financial Action Task Force (FATF) Recommendations and Guidance for Trust and Company Service Providers
  • The EU Anti-Money Laundering Directives (AMLD), including the Fourth, Fifth, and Sixth Directives
  • Applicable national AML/CTF legislation in each jurisdiction in which we operate
  • United Nations and applicable national sanctions regimes, including those administered by OFAC, the EU, the UK OFSI, and the UN Security Council
  • The Common Reporting Standard (CRS) and FATCA where applicable to our clients’ structures

Our policies and procedures are reviewed and updated regularly to reflect changes in legislation, regulatory guidance, and evolving risk typologies.

3. Risk-Based Approach

We apply a risk-based approach to AML and KYC, assessing the money laundering and terrorist financing risk presented by each client, business relationship, and transaction. Risk factors considered include:

  • Client type, ownership structure, and beneficial ownership
  • Jurisdiction of incorporation, residence, and operation
  • Nature, purpose, and complexity of the services requested
  • Source of funds and source of wealth
  • Politically exposed person (PEP) status
  • Adverse media, sanctions, and regulatory enforcement history
  • Presence in high-risk or non-cooperative jurisdictions as identified by FATF

The level of due diligence applied is proportionate to the assessed risk. Higher-risk clients and arrangements are subject to enhanced due diligence, including senior management approval prior to onboarding.

4. Customer Due Diligence

We conduct customer due diligence (CDD) on all clients before establishing a business relationship, and on a risk-assessed basis throughout the duration of that relationship. Our standard CDD requirements include:

4.1 Individual Clients and Beneficial Owners

  • Certified copy of a valid government-issued photo identification document (passport or national identity card)
  • Proof of current residential address dated within three months (utility bill, bank statement, or official government correspondence)
  • Confirmation of source of funds and, for higher-risk clients, source of wealth
  • PEP and sanctions screening

4.2 Corporate Clients and Structures

  • Certificate of incorporation and constitutional documents (memorandum and articles of association or equivalent)
  • Register of directors and shareholders
  • Certified organisational structure chart disclosing all entities and beneficial owners
  • Identification documents for all directors, authorised signatories, and beneficial owners holding 10% or more (or as required by applicable law, 25% or more)
  • Proof of registered office and principal place of business
  • Description of business activities and anticipated transaction volumes

4.3 Trusts and Foundations

  • Trust deed or foundation charter
  • Identification of all parties: settlor(s), protector(s), trustee(s), and all known beneficiaries or class of beneficiaries
  • Evidence of source of trust assets

5. Enhanced Due Diligence

Enhanced due diligence (EDD) is applied where the assessed risk level is higher than standard. Circumstances requiring EDD include, but are not limited to:

  • Clients or beneficial owners who are politically exposed persons (PEPs) or immediate family members or close associates of PEPs
  • Clients with connections to FATF high-risk or monitored jurisdictions
  • Complex or unusual ownership structures without clear legitimate rationale
  • Transactions or arrangements involving significant cash components
  • Clients who are the subject of adverse media coverage related to financial crime, fraud, or regulatory action
  • Clients seeking services whose nature or scale is inconsistent with their known business profile

EDD may include independent verification of identity, senior management sign-off, additional source of wealth analysis, and increased frequency of ongoing monitoring.

6. Beneficial Ownership

We place particular emphasis on identifying and verifying the ultimate beneficial owners (UBOs) of all client entities. We will not establish or continue a business relationship where we cannot satisfactorily identify the natural persons who ultimately own or control a client entity.

We maintain up-to-date beneficial ownership records and require clients to notify us promptly of any material changes to their ownership or control structure.

7. Sanctions Screening

All prospective and existing clients, beneficial owners, directors, and related parties are screened against applicable sanctions lists prior to onboarding and on an ongoing basis throughout the relationship. We will not establish or continue a relationship with any individual or entity that is subject to applicable financial sanctions, asset freezes, or travel bans.

Our sanctions screening encompasses the lists published by the United Nations Security Council, the European Union, the United States Office of Foreign Assets Control (OFAC), the United Kingdom Office of Financial Sanctions Implementation (OFSI), and other applicable national authorities.

8. Ongoing Monitoring

We conduct ongoing monitoring of existing client relationships, including:

  • Periodic review and refresh of client due diligence documentation, with the frequency determined by risk level
  • Monitoring of client activity and transactions for consistency with the stated business profile and expected patterns
  • Continuous adverse media and sanctions screening
  • Trigger-based reviews upon material changes to the client’s profile, ownership, or business activities

9. Suspicious Activity Reporting

We are legally required to file Suspicious Activity Reports (SARs) or equivalent disclosures with the relevant financial intelligence unit where we know, suspect, or have reasonable grounds to suspect that a person is engaged in money laundering or terrorist financing.

We are prohibited by law from disclosing to any client or third party that a SAR has been filed, or that we are considering filing one. This “tipping-off” prohibition is absolute and takes precedence over any contractual or confidentiality obligations.

10. Record Keeping

We retain all customer due diligence documentation, transaction records, and related correspondence for a minimum of five (5) years following the end of the client relationship, in accordance with applicable AML legislation. Records may be retained for longer where required by law or for the purposes of legal proceedings.

11. Staff Training and Governance

All Elaris staff who are involved in client-facing activities or the administration of client structures receive regular AML and CTF training commensurate with their roles and responsibilities. Training covers applicable law, red flag indicators, internal reporting procedures, and record-keeping obligations.

We have appointed a designated Money Laundering Reporting Officer (MLRO) who is responsible for receiving internal suspicious activity disclosures, making external reports to the relevant authorities, and overseeing the firm’s AML compliance programme. The MLRO reports directly to senior management.

12. Non-Co-operation and Refusal of Business

We reserve the right to decline to act for, or to terminate a relationship with, any client where:

  • We are unable to obtain satisfactory customer due diligence within a reasonable timeframe
  • The client refuses to provide required documentation or information
  • We have concerns regarding the source of funds or the legitimacy of the client’s activities
  • Continuing the relationship would require us to act in a manner inconsistent with our legal or regulatory obligations

In such circumstances, we may be required to file a SAR and, subject to the tipping-off provisions, to terminate the relationship without providing a reason.

13. Contact

Enquiries regarding our AML and KYC requirements should be directed to your relationship contact at Elaris, or to our compliance team at:

Compliance Department
Elaris Corporate Services
compliance@elariscorporate.com