AML & CTF Policy

1. Policy Statement & Regulatory Obligations

Capital Corporation Pty Ltd ("Capitals.au") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance. We operate under the following regulatory frameworks:

2. Know Your Customer (KYC) Requirements

We are required by law to verify the identity of all clients before providing financial services. Our KYC process includes:

3. Customer Due Diligence (CDD)

We apply a risk-based approach to customer due diligence, categorising clients as:

4. Ongoing Monitoring

We continuously monitor client accounts and transactions for suspicious activity. Our monitoring programme includes:

• Automated transaction monitoring systems that flag unusual patterns
• Regular review of client risk profiles and KYC documentation
• Screening against international sanctions lists (OFAC, UN, EU, DFAT, HM Treasury)
• PEP screening and adverse media monitoring
• Periodic re-verification of client identity for high-risk accounts

5. Suspicious Activity Reporting

We are legally required to report suspicious transactions to AUSTRAC (Australia) and the National Crime Agency (NCA) via Suspicious Activity Reports (SARs) in the UK. We are prohibited by law from tipping off clients that a report has been made. Failure to report suspicious activity is a criminal offence.

Suspicious activity includes but is not limited to: structuring transactions to avoid reporting thresholds, deposits from unknown or third-party sources, requests to withdraw funds to different accounts, and transactions inconsistent with a client's stated profile.

6. Prohibited Jurisdictions

We do not accept clients from jurisdictions subject to comprehensive international sanctions or identified by the Financial Action Task Force (FATF) as high-risk or non-cooperative. This list is reviewed and updated regularly. Current prohibited jurisdictions include those on the FATF "black list" and "grey list", as well as countries subject to OFAC, UN, EU, or Australian DFAT sanctions.

7. Politically Exposed Persons (PEPs)

Politically Exposed Persons (PEPs) — including current or former senior government officials, senior executives of state-owned enterprises, senior military officials, and their immediate family members and close associates — are subject to Enhanced Due Diligence. We require senior management approval before onboarding any PEP and apply enhanced ongoing monitoring throughout the relationship.

8. Record Keeping

In accordance with the AML/CTF Act 2006 and FCA Money Laundering Regulations, we retain all KYC documentation, transaction records, and AML-related correspondence for a minimum of 7 years from the date of the transaction or the end of the business relationship, whichever is later.

9. Staff Training

All Capitals.au staff with client-facing or compliance responsibilities receive regular AML/CTF training covering: recognition of suspicious activity, KYC procedures, sanctions screening, reporting obligations, and the legal consequences of non-compliance. Training records are maintained and reviewed annually.

10. Contact the AML Compliance Officer