AML Policy Statement

It is LINKTUM’s policy to prevent the misuse of LINKTUM’s or its counterparties’ facilities for the laundering of money or for the purpose of financing terrorist activities. LINKTUM is committed to full compliance with all applicable laws and regulations regarding the prevention of money laundering and terrorist financing. For these purposes, money laundering may include the conversion, transfer, concealment or retention of any funds or property knowing that the funds or property are derived from any activity that constitutes a criminal offence.

The term money laundering should be interpreted as including trade-based money laundering and terrorist financing, which refers to the process of disguising the proceeds of crime and moving value using trade transactions to legitimise their illegal origins or finance their activities.

If LINKTUM, LINKTUM counterparties, their personnel and/or facilities are misused for money laundering or terrorist financing, even inadvertently, this may give rise to legal consequences, including penalties.

With this in mind, LINKTUM conducts due diligence on all its counterparties. This includes verifying identity, understanding ownership structures, and ensuring the legitimacy of the individuals and entities we engage with. LINKTUM’s procedures are as follows:

• Identification and Verification: LINKTUM will need to obtain and verify your identification documentation and, where applicable, from your beneficial owners and individuals instructing on your behalf. This ensures that LINKTUM understands who it lawfully deals with.
• Documentation Requirements: Original documents are generally required for verification purposes, although LINKTUM also uses third-party electronic verification systems for convenience and efficiency.
• Third-Party Providers: To assist in these checks, LINKTUM works with reputable external databases and third-party providers who support it in verifying client identities and conducting ongoing monitoring.

LINKTUM’s commitment to compliance extends beyond initial due diligence. LINKTUM conducts regular risk assessments and ongoing monitoring of all relationships to ensure compliance with applicable regulations. This may include:

• Updated Documentation: Requesting up-to-date identity documents.
• Risk-Based Assessment: Tailoring ongoing monitoring efforts according to the assessed risk level of each counterparty.
• Understanding Source of Wealth and Funds: LINKTUM will need to establish the source of funds involved in any transactions, as well as the overall source of counterparty’s wealth. LINKTUM may require detailed information regarding the origin of the funds used in a transaction or the general source of a counterparty’s wealth.

LINKTUM recognizes the importance of fostering positive business relationships and the need to maintain the confidence of the many institutions with which it does business. LINKTUM will not intentionally work with any individual or organization that is not committed to preventing the facilitation of money laundering.

For more information, please contact us at info@linktum.com.