1. Introduction

Solvent.Life LTD, based in the United Kingdom at 100 Bishopsgate, 1808, Floor 18, EC2N 4AG London, is committed to adhering to the highest standards of anti-money laundering (AML) and combating the financing of terrorism (CFT) practices. This policy outlines the procedures and measures in place to prevent and detect money laundering and terrorist financing activities in compliance with UK laws and regulations.

2. Objectives

Prevent Solvent.Life LTD from being used for money laundering or terrorist financing.

Ensure compliance with the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as well as other applicable laws and regulations.

Protect the integrity and reputation of Solvent.Life LTD.

3. Scope

This policy applies to all employees, directors, and officers of Solvent.Life LTD. It covers all proprietary trading activities and software development operations, including artificial intelligence products.

4. Customer Due Diligence (CDD)

Know Your Customer (KYC):

Verify the identity of all customers and counterparties before establishing a business relationship.

Collect and verify information such as name, address, date of birth, and identification documents (e.g., passport, driving license).

For corporate clients, verify the identity of the company, its directors, and beneficial owners.

Enhanced Due Diligence (EDD):

Apply additional scrutiny to high-risk customers, including politically exposed persons (PEPs) and those from high-risk jurisdictions identified by the Financial Action Task Force (FATF).

Obtain additional information on the source of funds, the purpose of transactions, and the intended nature of the business relationship.

5. Transaction Monitoring

Implement automated systems to monitor trading and software licensing transactions for suspicious activity, including large, unusual, or unexpected transactions.

Conduct periodic reviews and analysis of transaction patterns to identify potential money laundering or terrorist financing activities.

6. Reporting

Suspicious Activity Reports (SARs):

Report any suspicious transactions to the National Crime Agency (NCA) promptly.

Ensure all SARs are documented and maintained for a minimum of five years.

Currency Transaction Reports (CTRs):

Report all transactions above the regulatory threshold (e.g., £10,000) to the relevant authorities.

Maintain records of all CTRs for a minimum of five years.

7. Record Keeping

Maintain comprehensive records of all transactions, customer identification, and due diligence information for at least five years from the end of the business relationship or the date of the transaction.

Ensure records are easily accessible and available to regulatory authorities upon request.

8. Risk Assessment

Conduct regular risk assessments to identify and mitigate risks of money laundering and terrorist financing associated with proprietary trading and software development operations.

Update risk assessments periodically and whenever there are significant changes in business operations or regulatory requirements.

9. Internal Controls and Compliance

Develop and implement internal policies, procedures, and controls to ensure compliance with AML/CFT regulations.

Appoint a compliance officer responsible for overseeing AML/CFT compliance, reporting to senior management, and liaising with regulatory authorities.

10. Training

Provide ongoing training to all employees on AML/CFT policies, procedures, and regulatory requirements.

Ensure employees understand how to identify and report suspicious activities and are aware of the specific risks associated with proprietary trading and AI software development.

11. Independent Audit

Conduct regular independent audits of the AML/CFT program to assess its effectiveness and identify areas for improvement.

Ensure audit findings are reported to senior management and appropriate corrective actions are taken.

12. Sanctions Compliance

Screen customers and transactions against relevant sanctions lists, including those maintained by the UK government, the United Nations, and the European Union, to ensure compliance with international sanctions and embargoes.

Implement procedures to promptly report and freeze any assets related to sanctioned individuals or entities.

13. Policy Review

Review and update this AML/CFT policy annually or whenever there are significant changes in regulatory requirements or business operations.

Ensure any updates are communicated to all employees and relevant stakeholders.

14. Compliance Officer

Contact Information: legal@solvent.life

Responsibilities: Overseeing AML/CFT compliance, conducting risk assessments, training employees, and liaising with regulatory authorities.

15. Conclusion

Solvent.Life LTD is committed to maintaining a robust AML/CFT program to protect the company, its customers, and the financial system from the risks of money laundering and terrorist financing. All employees are required to adhere to this policy and report any suspicious activities to the compliance officer immediately.