AML/KYC Policy

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines the procedures Landstoxx Ltd follows to prevent and detect money laundering, terrorist financing, and other illicit financial activities. This policy is mandatory for all users of the platform.

1. Policy Statement

Landstoxx is fully committed to complying with all applicable laws and regulations regarding AML and the countering of terrorist financing (CTF), including the UK's **Proceeds of Crime Act 2002**, the **Terrorism Act 2000**, and the **Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017**.

2. KYC: Customer Due Diligence (CDD)

Before any user can invest or raise funds, we must verify their identity. Our KYC process includes:

For Individual Users:

• Identity Verification: We require a valid, government-issued photo ID (e.g., passport, driving licence).
• Address Verification: We require a recent utility bill or bank statement (dated within the last 3 months).
• Source of Funds: For larger investments, we may request evidence of the source of your wealth/funds.

For Corporate/Institutional Users:

• Company registration documents and certificate of incorporation.
• Identification of ultimate beneficial owners (UBOs) and key controllers.
• Verification of the identity of directors and UBOs.

3. Ongoing Monitoring

Our AML/KYC obligations do not end after the initial verification. We conduct ongoing monitoring of user accounts and transactions to detect suspicious activity. This includes:

• Screening against sanctions lists and Politically Exposed Persons (PEPs) databases.
• Monitoring transaction patterns for unusual or high-risk behaviour.
• Periodically re-verifying customer information.

4. Enhanced Due Diligence (EDD)

EDD involves gathering more detailed information on the source of funds and the nature of the business relationship.

5. Reporting Suspicious Activity

All Landstoxx employees are trained to identify and report suspicious activity. If we suspect that funds are related to criminal activity, we are legally required to file a **Suspicious Activity Report (SAR)** with the **National Crime Agency (NCA)** without notifying the user involved ("tipping off").

6. Record Keeping

We securely maintain all KYC documents, transaction records, and AML-related correspondence for a minimum of **five years** after the end of the business relationship, as required by law.

7. AML Compliance Officer (MLRO)

Landstoxx has appointed a Money Laundering Reporting Officer (MLRO) who is responsible for the oversight of our AML/KYC program. The MLRO's responsibilities include policy implementation, staff training, and acting as the point of contact for law enforcement and regulatory agencies.