Anti-Money Laundering, KYC and Sanctions Policy

Kontino does not tolerate money laundering, terrorist financing, corruption, fraud or sanctions evasion. The program follows a risk-based approach and the requirements of the licensed Providers that execute the financial services, which maintain their own programs and may require additional controls.

• A designated compliance officer with independence and direct access to management.
• Policy, risk assessment and procedures reviewed at least annually or upon material changes in product, market or regulation.
• Mandatory annual training for staff working with customers, operations or technology.
• Periodic independent testing of the program.

• Individuals: name, date of birth, address, government-issued photo ID, tax number and liveness check.
• Businesses: formation documents, tax registration, address, directors, ultimate beneficial owners with 25% or more (or who otherwise exercise control), business activity, source of funds and expected volume.
• Connect partners: in addition to KYB, a call with the team, their own AML policy, licenses required in the countries where they operate, bank statements and group structure chart, depending on the operating model.
• Enhanced due diligence for high-risk customers, politically exposed persons and restricted industries, with compliance approval.

Customers, ultimate beneficial owners and counterparties are screened at onboarding and on an ongoing basis against sanctions lists (such as OFAC, UN, European Union and United Kingdom) and politically exposed persons lists.

We do not serve sanctioned persons or entities, or transactions involving comprehensively sanctioned jurisdictions or sanctioned regions, including Cuba, Iran, North Korea, Syria and the Crimea, Donetsk and Luhansk regions.

Transactions are monitored through rules and human review: volume and frequency outside the expected profile, structuring, high-risk counterparties, data inconsistencies and fraud-related patterns. Initial limits increase with history.

Suspicious transactions may be blocked, reversed or reported to the competent authorities, directly or through the Providers, without notice to the customer where the law prohibits it.

We keep identification, transaction and review records for the legally required period (generally 5 years after the end of the relationship), available to Providers and authorities when required.

Provide true information, respond to information requests within 5 business days and report changes in control, activity or volume. Partners under the aggregator model are responsible for verifying their own customers and must maintain an AML program consistent with this policy.

Suspect misuse of the platform? Write to compliance@kontino.co. Reports are handled confidentially and without retaliation.