Our approach to AML and CFT

Purpose

Solowise operates in a number of different jurisdictions, which often have differing Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) requirements. This public document therefore details our approach to AML & CFT generally across Solowise and common steps we apply as part of our AML & CFT commitment.

Introduction

A risk-based approach is required, with risk-based rules and criteria to proportionately manage Money Laundering (“ML”) and Financing Of Terrorism (“FT”) risk.

Solowise Approach

Solowise applies a risk-based approach to focus effort where it is most needed and will have the most impact.

This approach involves a number of steps to assess the most proportionate way to manage and mitigate the ML and FT risks faced by Solowise:

Identifying the ML and FT risks relevant to our operations;
Designing and implementing policies, procedures, and processes to manage and mitigate the risks;
Monitoring and improving the effective operation of these controls;
Recording what has been done, and why.

Solowise approach to ML and FT is outlined as part of a four-stage approach for both our EU and International operations. This includes:

Solowise Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Policy: This policy expresses our internal commitment to implementing strong measures to prevent the laundering of criminal proceeds. If such activities cannot be fully prevented, the policy ensures that we report incidents in compliance with our legal obligations.
Ongoing Risk Assessment: Our risk assessment process is continuous, focusing on potential ways the company could be exploited for money laundering or terrorist financing (ML/FT) activities. Specifically tailored to our Solowise platformsplaFTorms, these assessments form the foundation for creating and maintaining procedures that identify and address potential risks. The assessment process also considers risk evaluations provided by regulators or supervisory bodies.
AML Processes: These processes outline the specific practical systems and procedures tailored to each jurisdiction and division, aimed at monitoring customer activity. The goal is to identify any suspicious or concerning activities and conduct further investigations as necessary.
AML Operations Guidance: This guidance is designed for internal stakeholders, detailing our AML structure, legal obligations, protocols for reporting suspicious activities, and an overview of the procedures established to detect and mitigate ML/FT risks.

How we detect and prevent money laundering

Our AML/CFT Policy sets forth the essential standards that Solowise, along with all its subsidiaries and affiliated entities, must adhere to. These standards include:

Global Customer and Transaction Screening: Solowise is committed to screening all customers and applicable transactions within Solowise Platform across its global operations against sanctions lists from major bodies such as the United Nations, European Union, United Kingdom, and United States.
Local Sanctions Compliance: In addition to global screening, Solowise ensures compliance with local sanctions lists relevant to its operations within specific jurisdictions.
Prohibition of Certain Business Activities: Solowise strictly prohibits engaging in or facilitating any business activities, including starting or continuing customer relationships, providing products or services, or processing transactions that violate applicable sanctions laws or Solowise’s internal AML/CFT Policy. This includes activities involving individuals or entities listed on sanctions lists, as well as any transactions, directly or indirectly, linked to countries or territories under comprehensive sanctions programs. Currently, these regions include Cuba, Iran, North Korea, Syria, and the territories of Crimea, Donetsk, Luhansk, Kherson, and Zaporizhzhia, Eritrea, Iraq, Lebanon, Libya, Mali, Russia, Belarus, Somalia, South Sudan, Sudan, as well as other high-risk countries and territories.
Restrictions on Specific Transactions within Solowise Platform: Transactions involving, directly or indirectly, countries or individuals under selective or targeted sanctions programs are subject to restrictions. These programs often prohibit specific transactions and services related to particular products, industries, or government entities. Examples include:some text
- Certain activities involving the Government of Venezuela, as well as individuals connected with the Maduro regime.
- Financial dealings with the governments of Russia, Belarus, Libya, Sudan, or Zimbabwe.
- Transactions linked to the Russian financial, energy, defence and other sectors.
Investigation of Alerts: Any customer or client alerts or transactions within Solowise Platform lagged by Solowise’s screening systems are subject to investigation. While Solowise strives to resolve these cases promptly, compliance with sanctions laws or internal policies may necessitate delays for additional due diligence and information gathering.
Blocking and Rejecting Solowise Transactions: Solowise will block or reject transactions that are mandated under applicable sanctions laws and regulations or according to its own AML/CFT Policy. Even in cases where freezing or reporting obligations are not present, Solowise may return transactions deemed outside its risk tolerance.
Record-keeping of Sanctions/AML Breaches: Any breaches of AML or sanctions laws, including attempts by customers to evade these laws, are recorded by Solowise to maintain due record keeping in respect of such breaches.

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