AML Compliance
Anti-Money Laundering (AML) Policy
Our Commitment: Somnia ServiceCo. Ltd., Somnia TokenCo. Ltd., and Somnia NetworkCo. Ltd. (collectively, the "Companies") are committed to maintaining the highest standards of compliance with anti-money laundering (AML), counter-terrorism financing (CFT), and sanctions laws. We implement robust policies and procedures to prevent our services from being misused for illicit purposes.
Policy Overview: As companies incorporated in the British Virgin Islands, we voluntarily adopt comprehensive AML/CFT compliance measures as a matter of best practice, implementing policies based on international standards and regulatory frameworks.
KEY PRINCIPLES
Risk-Based Approach: We employ a comprehensive risk-based approach to identify, assess, and mitigate money laundering, terrorist financing, and proliferation financing risks across our operations, including:
Customer due diligence assessments
Geographic risk evaluation
Product and service risk analysis
Transaction monitoring
Know Your Customer (KYC): We conduct thorough customer identification and verification procedures for all clients, including:
Identity verification
Beneficial ownership identification
Sanctions screening
Enhanced due diligence for high-risk customers
Ongoing Monitoring: We maintain continuous monitoring of business relationships and transactions to:
Detect unusual or suspicious activities
Ensure consistency with customer profiles
Update customer information regularly
Screen against sanctions lists
COMPLIANCE FRAMEWORK
Prohibited Activities: We do not engage in business relationships or transactions with:
Individuals or entities on sanctions lists
Politically Exposed Persons (PEPs) without enhanced due diligence
Customers from high-risk jurisdictions without appropriate controls
Any party involved in money laundering, terrorist financing, or other illicit activities
Enhanced Due Diligence: We apply enhanced due diligence measures for:
High-risk jurisdictions (including but not limited to Burma, Iran, North Korea)
Politically Exposed Persons and their associates
Complex corporate structures
Unusual transaction patterns
Record Keeping: We maintain comprehensive records of:
Customer identification and verification documents
Transaction records
Compliance documentation
Suspicious activity reports
All records are retained for a minimum of five years in secure, confidential systems.
REPORTING
Suspicious Activity: We have established procedures for identifying and reporting suspicious activities to relevant authorities. All employees are trained to recognize red flags and report concerns through appropriate channels.
Regulatory Cooperation: We maintain full cooperation with regulatory authorities and law enforcement agencies, responding promptly to information requests and regulatory inquiries.
TRAINING AND AWARENESS
All relevant personnel receive regular AML/CFT training to ensure:
Understanding of legal obligations
Recognition of suspicious activities
Proper implementation of compliance procedures
Awareness of emerging risks and threats
CONTACT
For compliance-related inquiries or to report suspicious activities:
Money Laundering Reporting Officer (MLRO): Campbells Regulatory Services Limited Email: [email protected]
REGULATORY FRAMEWORK
Our compliance program is designed to meet the requirements of applicable laws and regulations, including:
BVI Anti-Money Laundering Regulations
BVI Anti-Money Laundering and Terrorist Financing Code of Practice
International sanctions regimes
FATF Recommendations
We regularly review and update our AML/CFT policies and procedures to ensure they remain effective and compliant with evolving regulatory requirements and industry best practices.
This policy is effective as of the date of publication and is subject to periodic review and updates. For the most current version, please visit this page from time to time.
Last updated