[email protected]
Company No: 16879782

Anti-Money Laundering Policy

Our commitment to preventing financial crime and maintaining regulatory compliance.

Home / AML Policy

Last updated: 28 November 2025

1. Introduction

SKD International Ltd is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our approach to preventing the use of our services for money laundering, terrorist financing, or other financial crimes.

As a UK-registered company (No. 16879782), we comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended), the Proceeds of Crime Act 2002, and the Terrorism Act 2000.

2. Risk Assessment

We conduct regular risk assessments to identify and mitigate money laundering and terrorist financing risks associated with our business activities. Our risk assessment considers:

  • Customer risk profiles and geographic locations
  • Product and service risk (digital top-up, API services)
  • Transaction patterns and volume analysis
  • Delivery channel risks

3. Know Your Customer (KYC)

We carry out Customer Due Diligence (CDD) on all business clients before establishing a business relationship. Our KYC process includes:

3.1 Standard Due Diligence

  • Identification and verification of the customer's identity
  • Identification and verification of beneficial owners
  • Assessment of the purpose and intended nature of the business relationship
  • Verification of business registration documents

3.2 Enhanced Due Diligence (EDD)

We apply enhanced due diligence measures for higher-risk clients, including:

  • Politically Exposed Persons (PEPs) and their associates
  • Clients from high-risk jurisdictions
  • Complex or unusually large transactions
  • Clients with unusual business structures

4. Transaction Monitoring

We employ automated systems to monitor transactions for suspicious activity. Our monitoring includes:

  • Real-time transaction screening against sanctions lists
  • Pattern detection for unusual transaction volumes or frequencies
  • Monitoring for structuring or layering indicators
  • Automated alerts for transactions exceeding defined thresholds
  • Periodic review of dormant accounts and sudden activity changes

5. Sanctions Screening

We screen all customers and transactions against applicable sanctions lists, including:

  • HM Treasury sanctions list
  • UN Security Council sanctions list
  • EU sanctions list
  • OFAC (US Office of Foreign Assets Control) SDN list

6. Suspicious Activity Reporting

Where we identify suspicious activity, we:

  • Submit Suspicious Activity Reports (SARs) to the National Crime Agency (NCA)
  • Do not "tip off" the customer about the SAR
  • Maintain appropriate records of all reports filed
  • Cooperate fully with law enforcement authorities

7. Record Keeping

We maintain all CDD records and transaction data for a minimum of 5 years after the end of the business relationship or the date of the transaction, in compliance with UK regulations.

8. Staff Training

All relevant staff receive regular AML/CTF training covering:

  • Legal and regulatory obligations
  • Recognising and reporting suspicious activity
  • Customer due diligence procedures
  • Updates to regulations and company policies

9. Compliance Officer

We have appointed a Money Laundering Reporting Officer (MLRO) responsible for:

  • Overseeing AML/CTF compliance programme
  • Receiving and assessing internal suspicious activity reports
  • Filing SARs with the NCA where appropriate
  • Ensuring policies and procedures remain up to date

10. Contact

For questions about our AML policy or to report concerns, please contact:

SKD International Ltd — Compliance Department
Email: [email protected]
Address: Suite 10247, 5 Brayford Square, London, E1 0SG, United Kingdom