Anti-Money Laundering and Sanctions Policy

1. Who we check

Every party we introduce — project owners, sponsors and investors — and, for organisations, the individuals who own or control them.

2. What we check

• Identity: government-issued identification for individuals, and incorporation documents and ownership details for organisations, including beneficial owners holding 10% or more.
• Sanctions: screening against the UN Security Council, US OFAC, UK HM Treasury and EU consolidated sanctions lists.
• Politically exposed persons: whether a party, or someone closely associated with them, holds or has held a prominent public function.
• Adverse media and the source of funds or wealth, where a party presents a higher risk.

3. When we check

Before any introduction, and again when a check expires or circumstances change. Checks are renewed periodically, and a party whose checks are incomplete, expired or adverse is not introduced.

4. What we do with the results

• Every check is recorded: what was checked, the result, who carried it out and when. A re-check creates a new record; earlier checks are kept, not overwritten.
• An adverse result is escalated to a senior member of our team for a documented decision before anything proceeds.
• We keep verification records for 7 years after a relationship ends. Copies of identity documents are kept for 12 months, or less once the check they support is superseded.
• Where the law requires, we report suspicions to the Financial Reporting Centre (Kenya) or the relevant authority, and we will not tell the person concerned.

5. What we will not do

We will not work with shell banks, sanctioned persons or entities, or anyone who refuses to provide the information we need, and we will not facilitate a transaction we suspect is connected to crime.

6. Contact

Compliance questions: info@crestlinegroup.sbs.