ANTI-MONEY LAUNDERING (AML) & COUNTER-TERRIST FINANCING (CTF) POLICY

Last Updated: 19 July 2026

1. Statement of Commitment

Kukka Capital ("the Company") is strictly committed to preventing the use of its platform, services, and networks for money laundering, terrorist financing, or any other financial crimes. We operate in strict accordance with applicable international standards and local regulations, including but not limited to the [Insert Local Law, e.g., UK Money Laundering Regulations].

2. Money Laundering Reporting Officer (MLRO)

The Company shall appoint a Money Laundering Reporting Officer (MLRO) who will be responsible for:

  • Overseeing the Company’s compliance with AML/CTF laws and regulations.

  • Receiving, analyzing, and investigating internal reports of suspicious activity.

  • Filing Suspicious Activity Reports (SARs) with the relevant financial intelligence units.

3. Customer Due Diligence (CDD) & Know Your Customer (KYC)

The Company applies a Risk-Based Approach (RBA) to identify and verify all clients before establishing a business relationship.

  • Standard Identification: Verification of individual clients requires a valid government-issued photo ID (passport or driving license) and a proof of address (utility bill or bank statement issued within the last 3 months).

  • Corporate Clients: Verification requires certificate of incorporation, articles of association, and proof of identity for all Ultimate Beneficial Owners (UBOs) holding more than 25% of the shares or voting rights.

  • Sanctions & PEP Screening: All clients are screened against global sanctions lists (e.g., OFAC, UN, EU, HM Treasury) and Politically Exposed Persons (PEPs) lists. We do not onboard individuals or entities subject to financial sanctions.

4. Enhanced Due Diligence (EDD)

We apply Enhanced Due Diligence (EDD) to clients classified as high-risk, including PEPs, clients from high-risk jurisdictions, or those conducting unusually large transactions. EDD measures include:

  • Obtaining additional information on the source of wealth or source of funds (e.g., tax returns, bank statements, corporate financial audits).

  • Requiring senior management approval to open or maintain the account.

5. Transaction Monitoring & Prohibited Activities

The Company continuously monitors trading behaviors and transactional movements (deposits, payouts, and transfers) to detect anomalies. Prohibited activities include:

  • Third-Party Payments: Deposits and payouts must only be made to/from accounts held in the exact name of the registered Kukka Capital client. Third-party transactions are strictly prohibited.

  • Structuring / Smurfing: Artificially breaking down large financial movements into smaller transactions to evade thresholds.

  • Shell Banks: The Company does not maintain relationships with, or accept funds from, shell banks.

6. Record Keeping

All records relating to client identification (KYC documents), transaction histories, risk assessments, and internal/external suspicious activity investigations will be retained for a minimum of [Insert Number, e.g., 5 years] following the termination of the business relationship.