AML & KYC Policy

Protect against money laundering and know your customer policy (AML & KYC)

To protect our clients’ assets and ensure compliance with international trade standards, we work exclusively in accordance with anti-money laundering and anti-terrorist financing legislation. In order to monitor in accordance with the legal requirements and recommendations of the FATF, we have created a compliance department, developing procedures to combat money laundering and knowledge of your customers (AML / KYC), mandatory for all employees and determining the policy of engagement with each person which is registered on the website www.stkcif.com. The Compliance Department aims to ensure that all operations of the Company are in accordance with international standards for combating money laundering and all documents provided by the Client are up to date and comply with applicable laws. requirements. By registering on our Website, the Client fully and unconditionally accepts the terms of the policy, agrees with the following rules and undertakes to comply with them:

All customers are not treated in the same way, therefore the anti-money laundering (AML) requirements are the same. The only difference may be the levels (levels) for requesting additional information from customers with inaccurate and unclear documentation. The specific requirements are set out in Appendix 1 to this anti-fraud policy.

If you successfully pass the KYC that is associated with that level, you will receive all the benefits provided for that level. We usually try to perform KYC procedures as soon as possible, but in some circumstances this may take several days;

If you are a corporate or institutional client, please follow the requirements of Annex 2 to this policy to combat and combat the former client.

At the request of the Company, the additional documents and information must be provided by the Client. Completion of the relevant KYC questionnaire may also be a mandatory requirement under the sole decision of the company. The Client agrees with such requirements of the Company and agrees to comply with them;

Withdrawal of Assets is performed only on an account that belongs to a person designated as a Client of the Company. Withdrawal of third party assets is prohibited. Internal transfers between the Company’s customers are also prohibited.

The Company is obliged and has the right without prior consent to share with financial institutions and law enforcement authorities any information about the Client, as required by applicable law, and the Client gives the Company his consent to these actions. To comply with this paragraph, the Company shall keep records of the customer’s transactions for at least five years.

The client undertakes to comply with the law, including international law, aimed at combating illegal trafficking, financial fraud, money laundering and money laundering. The Client undertakes to make every effort to avoid direct or indirect participation in illegal financial activities and any illegal transactions using the Company’s website and services.

The Client guarantees the legal origin, the legal property and the right to use the Assets transferred to his account.

In case of evidence of suspicious transactions on the Client’s account, replenishment of money from unreliable sources (for example, the data of the sender of the assets and the owner are different) and / or any actions with signs of fraud (including refund or cancellation) payments, the Company reserves the right to conduct an internal investigation, to block or close the Client or any Account, to cancel any payment or transaction and to suspend the operations on the Accounts before the end of the official investigation. In making its decision, the Company is guided by the provisions of applicable law, FATF recommendations or general practice.

 The Company also reserves the right to block the Client or a business transaction during the investigation if the Client refuses to provide the additional information requested by the Company.

In the course of the investigation the Company has the right to request additional copies of documents confirming the identity of the Client. The Company also has the right to require the submission of original documents for review in case of doubt by the Company.

The Company does not provide services to persons located in jurisdictions identified by the FATF as high-risk and non-cooperative jurisdictions with strategic AML / CFT deficiencies, namely: Afghanistan, American Samoa, Bahamas, Botswana, Democratic People’s Republic of Korea, Ethiopia , Ghana, Guam, Iran, Iraq, Libya, Nigeria, Pakistan, Panama, Puerto Rico, Samoa, Sri Lanka, Syria, Trinidad and Tobago, Tunisia, US Virgin Islands, Yemen.


The company does not provide services to US citizens and residents.

The refusal of the Company to perform the operations, which from the point of view of the Company are considered suspicious, the use of preventive measures is not a reason for civil liability of the Company for non-fulfillment of obligations to the Client.

The Company is not obliged to inform the Client or other persons about the measures taken to implement the legislation in the field of AML / CFT. Also, the Company is not obliged to inform Clients or other persons about any suspicions, about the reasons for refusal to execute commercial transactions and project management of Client, about refusal and need to provide documents to Client, etc.

This counteracts money laundering and know that your customer policy is an integral part of the customer agreement found on the website. Failure to comply with this policy may be grounds for termination of the customer agreement at the sole discretion of the Company.

Application 2

Verification measures for corporate and institutional clients

This policy applies only to corporate and institutional clients. This category of customers must go through the mandatory intensive inspection process.

We reserve the right to refuse to provide services to you if during the verification process it is determined that you do not meet our requirements for KYC. We also have the right to terminate our existing relationship with you at any time in the event that you are deemed to be in breach of our KYC requirements.

At our request, all additional documents and information must be provided by you and if you refuse to provide such documents or information, this may also lead to our refusal or termination of the provision of services.

The following supporting documentation must accompany the completed questionnaire to the client:

  • Memorandum and Articles of Association;
  • Registration certificate;
  • Certificate of workload (dated from the last 3 months);
  • Proof of operating address (original utility bill, showing the name of the company and the operating address from the last three months or a lease agreement in case you rent office space);
  • Document for appointment of the director (minutes, decision of the shareholders, etc.);
  • Individual inspection of an authorized representative (copy of passport);
  • Individual check of all active directors (copy of passport and recent original utility bill for each);
  • Individual inspection of shareholders / beneficiaries with ownership of 25% or more:

– Individual shareholders (copy of passport and recent original utility bill for each)

– Corporate shareholders (full list of supporting documentation for each company, as listed above);

For level 2 you must additionally provide:

Bank statement containing bank details of your company to be used in settlements with you.

Financial statements or bank statements of the company for the last three months; Other documents confirming the source of funds (company accounts, tax return, etc.);