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Anti-Money Laundering (AML) Policy

Effective Date: 14/02/2025

Issued by: ZenithWave Capital Limited
Company Address: Southbridge House, Southbridge Place, Croydon, CR0 4HA

1. Purpose & Scope

1.1 ZenithWave Capital Limited ("Company", "we", "our") is committed to preventing money laundering, terrorist financing, and other financial crimes.
1.2 This Anti-Money Laundering (AML) Policy outlines our procedures to detect, report, and mitigate financial crime risks in compliance with UK laws and regulations, including the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

2. Regulatory Compliance

2.1 The Company adheres to UK laws and guidelines set by:

  • The Financial Conduct Authority (FCA)
  • The National Crime Agency (NCA)
  • HM Revenue & Customs (HMRC)

2.2 We follow the Know Your Customer (KYC) and Customer Due Diligence (CDD) protocols to verify the identity of all clients.

3. Customer Due Diligence (CDD) & KYC Requirements

3.1 The Company will conduct due diligence before establishing any business relationship by verifying the identity of all clients and investors.
3.2 Clients must provide:

  • A valid government-issued ID (passport, driver’s license, or national ID)
  • Proof of address (utility bill, bank statement, or tenancy agreement)
  • Source of funds declaration (if applicable)

3.3 Enhanced Due Diligence (EDD) may be required for high-risk individuals, including politically exposed persons (PEPs).

4. Reporting & Monitoring

4.1 The Company continuously monitors transactions for suspicious activities, such as:

  • Large, unexplained deposits or withdrawals
  • Transactions involving high-risk countries
  • Attempts to evade KYC/AML procedures

4.2 Any suspicious transactions will be reported to the National Crime Agency (NCA) via a Suspicious Activity Report (SAR).

5. Record-Keeping

5.1 The Company will retain KYC, CDD, and transaction records for a minimum of five (5) years, as required by UK regulations.
5.2 These records will be kept confidential and securely stored, accessible only to authorized personnel.

6. Employee Training & Compliance

6.1 All employees and partners must undergo AML compliance training to recognize and report suspicious activities.
6.2 The Company’s designated Money Laundering Reporting Officer (MLRO) will oversee AML compliance and reporting procedures.

7. Penalties for Non-Compliance

7.1 Failure to comply with AML laws may result in severe penalties, including:

  • Fines and sanctions imposed by regulatory authorities
  • Legal prosecution for involvement in financial crime
  • Termination of business relationships with non-compliant clients

8. Policy Review & Updates

8.1 This AML Policy will be reviewed and updated annually to ensure compliance with evolving laws and best practices.

Contact

For any concerns regarding AML compliance, please contact us at compliance@zenithwavecapital.com.