AML and KYC policy
Anti-Money Laundering & Know Your Customer POLICY
INTRODUCTION
This AML/KYC Policy establishes the compliance standards and operational controls implemented by ASTRA GLOBAL HOLDING LTD (“the Company”), acting as a Payment Agent on behalf of a licensed Financial Institution (“FI”). The Company operates under and adheres to:UK Money Laundering Regulations (MLR 2017),FATF International Standards,English Law,The internal AML framework and risk appetite of the FI,All applicable AML/CFT regulations and guidance of the European Union.The Company does not conduct any regulated financial services. All regulated activities and final compliance decisions are performed exclusively by the FI.
1. PURPOSE & SCOPE
This Policy exists to prevent the Company’s platform, services, or partner channels from being used for:Money laundering,Terrorist financing,Sanctions evasion,Fraud, financial misconduct, or criminal activity.It outlines internal controls and procedures ensuring full compliance with UK, EU, and FATF AML/CFT rules, while supporting the FI in its regulatory obligations.
2. ROLES & RESPONSIBILITIES
Company ResponsibilitiesThe Company is responsible for:Collecting initial KYC and KYB documentation;Conducting preliminary customer screening (sanctions, PEP, adverse media);Identifying anomalies or red flags during onboarding;Escalating suspicious or incomplete cases to the FI;Following the FI’s instructions and AML policies;Maintaining secure records of all AML-relevant information.FI ResponsibilitiesThe Financial Institution is responsible for:Final onboarding decisions and customer approval;Full AML risk scoring and customer categorisation;Ongoing transaction monitoring;Filing Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs);Regulatory engagement and reporting.User ResponsibilitiesAll users must:Provide complete, accurate, and up-to-date documentation;Act honestly and transparently during onboarding;Avoid any illegal, fraudulent, or prohibited activity;Fully cooperate with AML/KYC investigations and requests for additional documents.
3. CUSTOMER DUE DILIGENCE (CDD)
For IndividualsValid Passport or Government-issued ID;Proof of Address (dated within 90 days);Biometric or live-liveness verification;Additional information when required by compliance.For Corporates (KYB)Certificate of Incorporation;Articles of Association;Official company registry extract;Identification of all Ultimate Beneficial Owners (UBOs);Detailed business and activity review.Mandatory AML DocumentationSource of Funds (SOF);Source of Wealth (SOW);Intended activity patterns and expected financial behaviour.
4. ENHANCED DUE DILIGENCE (EDD)
EDD is mandatory for higher-risk customers, including:Clients from high-risk jurisdictions;Politically Exposed Persons (PEPs);Companies with complex ownership structures;Clients demonstrating inconsistent or suspicious behaviour.EDD Methods May Include:Additional identity documents;Mandatory video call verification;Bank statements or bank reference letters;Tax documents or financial records;Detailed SOF/SOW validation;Independent database checks;Senior management approval.
5. SANCTIONS, PEP & ADVERSE MEDIA SCREENING
The Company screens customers using global and authoritative databases, including:OFAC (U.S. Treasury)OFSI (UK Sanctions List)EU Consolidated Sanctions ListUnited Nations SanctionsGlobal PEP databasesAdverse media and financial crime intelligence toolsScreening is performed at onboarding and may be repeated as required.
6. TRANSACTION MONITORING
Transaction monitoring is performed exclusively by the FI.
The Company may, however, identify and escalate:Unusual or inconsistent transaction patterns;Transfers involving high-risk jurisdictions;Potential structuring or layering attempts;Third-party payments or unexplained beneficiaries.Suspicious cases are escalated to the FI without delay.
7. RECORD KEEPING
The Company retains AML and KYC data in accordance with UK/EU law.Retention Period5–7 years, or longer where required by AML/CFT regulations or legal proceedings.Records MaintainedKYC/KYB documentsScreening logsInternal notes
Communications and correspondenceSOF/SOW informationEscalation historyRecords are stored securely and remain confidential.
8. RED FLAGS & SUSPICIOUS ACTIVITY
Examples of red flags include:Inconsistent, altered, or false documentation;Unwillingness to provide required AML data;Use of shell companies or complex structures without clear rationale;Sudden changes in behaviour or financial patterns;Links to PEPs, sanctioned entities, or high-risk jurisdictions;Evasive or non-cooperative behaviour.Any red flag triggers an immediate escalation to the FI.
9. REPORTING SUSPICIONS
In the event of suspicious activity:The Company will promptly notify the FI;Onboarding or access may be paused or terminated;The Company will not communicate details to the user (“no tipping-off”);The FI determines whether to file a SAR/STR to authorities.The Company does not file SARs directly unless legally required.
10. CONFIDENTIALITY & DATA PROTECTION
All AML/KYC data is:Stored securely with encryption;Restricted to authorised personnel only;Shared exclusively with regulators or the FI;Processed in accordance with UK GDPR, EU GDPR (where applicable), and international data protection standards.The Company implements strict confidentiality and data security procedures.
11. PROHIBITED ACTIVITIES
Users may not use the Company’s services for:Money laundering;Terrorist financing;Fraud or scam activity;Sanctions evasion;Tax evasion;Dark web transactions;Criminal or suspicious financial behaviour.Engaging in prohibited activity results in immediate termination and reporting.
12. RESTRICTED & HIGH-RISK COUNTRIESA. FATF BLACKLIST – ABSOLUTE PROHIBITION
No onboarding under any circumstances:IranNorth Korea (DPRK)
B. COMPANY PROHIBITED LIST — NO ONBOARDING PERMITTED
Onboarding is not allowed for individuals or entities connected to:RussiaAfghanistanIraqSomaliaSudanSyriaYemenLibyaEritreaMyanmarCubaVenezuelaThese jurisdictions represent extreme sanctions, corruption, and financial crime risk.
C. FATF GREY LIST — EDD REQUIRED
Jurisdictions requiring mandatory Enhanced Due Diligence include (non-exhaustive):NigeriaMozambiqueKenyaJamaicaSouth SudanNamibiaVietnamTurkey & Turks and CaicosCroatiaBulgariaPhilippinesEDD procedures must be followed before a final decision is made.
13. GOOD FAITH & USER LIABILITY
The User agrees to act with full honesty and transparency.
Any fraudulent, illegal, or abusive behaviour results in:Immediate termination,Reporting to the FI and authorities,Full legal and financial liability,Potential civil or criminal consequences.The Company and the FI reserve the right to seek compensation for damages or losses incurred.
14. ACTION ON SUSPICIOUS ACTIVITY
If suspicious behaviour is identified, the Company and/or FI may:Freeze or pause user onboarding;Terminate or reject the application;Block or restrict access;Return funds where legally required;Report the case to law enforcement or regulators;Share information under AML/CFT regulations;Initiate administrative or legal proceedings.These actions may be taken without prior notice where required by law.
15. POLICY REVIEW & UPDATES
This Policy is reviewed:Annually,When regulatory requirements change,When the FI updates its AML framework,When FATF lists or sanctions lists are updated,When operational or risk factors require adjustments.Updated versions take effect once published.
Contact Information ASTRA GLOBAL HOLDING LTD
Email: support@astra-global-holding-ltd.net
Address: 167-169 Great Portland Street, 5th Floor, London, W1W 5PF Reg.number: 16359197
This Policy is approved by the Management of the Company.