AML/CFT Policy
ANTI-MONEY LAUNDERING AND COMBATTING THE FINANCING OF TERRORISM POLICY
Last Revised: 22 June 2026
1. Policy Statement and Commitment
1.1. OTC International (the Company) is committed to preventing the misuse of its business activities, advisory services, investment-related services, and associated operations for money laundering, terrorist financing, corruption, or any other form of illicit financial activity.
1.2. The Company recognises that businesses providing advisory, corporate support, strategic investment, or transaction-related services may be exposed to money laundering and terrorist financing risks, including risks arising from complex ownership structures, cross-border transactions, and high-risk clients.
1.3. Accordingly, the Company adopts and implements this Anti-Money Laundering and Countering the Financing of Terrorism Policy (AML/CFT Policy) in accordance with:
● the AML/CFT Act, 2020, as amended and consolidated (Revised Edition as at 17 Jan 2025);● the AML/CFT Regulations and applicable guidance notes issued in Seychelles;
● sanctions obligations implemented pursuant to United Nations Security Council Resolutions;
● applicable directives, guidance notes, and advisories issued by the Seychelles Financial Intelligence Unit (FIU), the Financial Services Authority (FSA), and other competent authorities; and
● the Recommendations and Interpretive Notes of the Financial Action Task Force (FATF).
1.4. The Company adopts a risk-based approach to AML/CFT compliance and shall implement reasonable and proportionate controls commensurate with the nature, scale, and complexity of its operations.
2. DNFBP Status and Inherent Risk
2.1. The Company qualifies as a Designated Non-Financial Business and Profession (DNFBP) pursuant to Schedule 1, Part C, Section 9 of the AML/CFT Act, 2020 (Revised Edition as at 17 January 2025), as it carries on, by way of business, activities involving the investment, administration, or management of funds or money on behalf of third parties.
2.2. Such activities include the buying and selling of business entities; managing client money, securities, or other assets; organising contributions for the creation, operation, or management of companies; acting as, or arranging for another person to act as, a director, secretary, partner, trustee, or nominee shareholder; and providing registered office, business, correspondence, or administrative addresses for companies, partnerships, or other legal persons or arrangements.
2.3. The Company recognises that these activities present elevated inherent AML/CFT risks, particularly in relation to the concealment of beneficial ownership, misuse of nominee structures, third-party funding, and cross-border transactions. Accordingly, the Company applies enhanced risk-based controls and customer due diligence measures proportionate to these risks.
3. Scope of Application
3.1. This Policy applies to:
● The Company;
● All partners, directors, officers, employees, consultants, secondees, and authorised representatives;
● All DNFBP activities, services, transactions, and client relationships, whether ongoing or occasional; and
● All jurisdictions in which the Company operates or provides services.
3.2. Compliance with this Policy is mandatory and forms part of the Company’s internal governance and risk management framework. No commercial consideration shall override compliance obligations.
4. Compliance Culture
4.1. The Company is committed to fostering a strong culture of integrity, ethical conduct, and regulatory compliance throughout the organisation.
4.2. All personnel shall remain vigilant in identifying suspicious or unusual activity and shall promptly escalate concerns in accordance with this Policy.
4.3. No employee or representative shall knowingly engage in, facilitate, or ignore conduct that may constitute money laundering, terrorist financing, sanctions evasion, proliferation financing, fraud, or related criminal activity.
5.Governance and Responsibility
5.1. The General Manager shall have ultimate responsibility for overseeing and implementing the Company’s AML/CFT framework.
5.2. The responsibilities of the General Manager include:
● approving AML/CFT policies and controls;● ensuring adequate compliance resources;
● approving high-risk business relationships;
● overseeing risk assessments;
● ensuring appropriate record retention;
● overseeing staff training; and
● ensuring reporting obligations are fulfilled where applicable.
5.3. The Company may designate an AML Compliance Officer or AML Coordinator to administer day-to-day compliance functions, including:
● customer due diligence reviews;● enhanced due diligence procedures;
● sanctions and screening controls;
● transaction monitoring;
● maintenance of compliance records; and
● preparation of internal compliance memoranda and reports.
5.4. Delegation of operational responsibilities shall not relieve the General Manager of overall accountability for compliance.
5.5. All employees are required to comply with this Policy and immediately report suspicious activity, compliance breaches, or unusual conduct to the AML Compliance Officer or General Manager.
6. Risk-Based Approach
6.1. The Company applies a documented risk-based approach proportionate to its activities.
6.2. Customers shall be classified into three categories:
● Low Risk: Seychelles residents with transparent profiles and no adverse indicators.● Medium Risk: Foreign purchasers from jurisdictions not deemed high risk, where documentation and profile are consistent.
● High Risk: Politically Exposed Persons (PEPs), their relatives or close associates, customers from high-risk jurisdictions, cases of adverse media, or complex corporate structures.
6.3. No High-Risk relationship may be established unless the General Manager has reviewed the Enhanced Due Diligence file and provided written approval.
7. Customer Due Diligence (CDD)
7.1. The Company shall conduct CDD measures prior to:
● establishing a business relationship;● undertaking any occasional transaction above applicable thresholds;
● accepting funds or assets;
● entering into contractual arrangements; or
● where suspicion of money laundering or terrorist financing arises.
a. For Natural Persons: CDD measures for natural persons shall include:
● full legal name;
● nationality;
● date and place of birth;
● residential address;
● occupation or business activity;
● government-issued photographic identification; and
● verification of identity using reliable and independent source documents.
b. For Legal Persons: CDD measures for legal entities shall include:
● trade license or certificate of incorporation;
● constitutional documents;
● registered address;
● authorised signatories; and
● ownership and control structure.
7.2. All customers shall be screened through the Company’s AML Screening Software against global sanctions lists, PEP databases, and adverse media sources at onboarding, prior to the acceptance of payments, or periodically during the relationship.
8. Enhanced Due Diligence (EDD)
8.1. EDD shall be mandatory where customers are classified as High Risk.
8.2. EDD shall include:
● Verification of source of funds through acceptable documents such as bank statements, audited accounts, contracts of sale, or loan agreements;
● Verification of source of wealth through supporting records such as business ownership documentation, inheritance evidence, or tax declarations;
● Execution of a declaration of independence from public office where the customer is a PEP or a relative of a PEP;
● Preparation of a written EDD report and approval memorandum for consideration by the General Manager.
8.3. It is the policy of the Company that no transaction shall proceed unless and until satisfactory evidence of both the source of funds and the source of wealth has been obtained. 9.1 The Company shall treat all PEPs, whether in their own capacity or as immediate family members or close associates of such persons, as High Risk.
9.2 No relationship with a PEP shall be commenced or continued unless: 9.3 PEP relationships shall be subject to enhanced ongoing monitoring and periodic review at intervals not exceeding twelve (12) months.
10.1 The Company shall comply with all applicable sanctions obligations imposed pursuant to United Nations Security Council Resolutions (UNSCR) and applicable Seychelles laws and regulations.
10.2 The Company shall not knowingly engage in transactions involving: 10.3 Any confirmed sanctions match shall result in the immediate refusal or termination of the relationship.
11.1 The Company recognises that suspicious activity may arise in a variety of forms. Indicators include, but are not limited to:
11.2 Where suspicious activity is detected, the matter shall be escalated to the General Manager, who shall determine whether to suspend the transaction and escalate the matter to the Company’s banking partner for potential reporting to the Financial Intelligence Unit (FIU).
12.1 All AML/CFT records shall be retained for a minimum of seven (7) years, including: 12.2 Records shall be securely maintained and made available promptly upon lawful request by competent authorities.
13.1 Employees shall receive AML/CFT training upon onboarding and periodically thereafter. Employees reporting suspicions in good faith shall be protected from retaliation.
14.1 Failure to comply with this Policy may result in disciplinary action, termination, regulatory reporting, and legal consequences.
15.1 This Policy shall be reviewed at least annually by the General Manager to ensure its continued effectiveness and compliance with applicable legal and regulatory requirements.
15.2 Interim reviews shall be conducted where required due to changes in applicable laws, regulations, regulatory guidance, or updates to the Recommendations of the FATF.
9. Politically Exposed Persons (PEPs)
● EDD has been completed in accordance with applicable regulatory requirements; and
● Written approval of the General Manager, based on the EDD Report and supporting documentation.
10. Sanctions Compliance
● sanctioned individuals or entities;
● prohibited jurisdictions;
● terrorism financing;
● proliferation financing; or
● sanctions evasion activities.
11. Suspicious Transactions
● Complex ownership or control structures, including the use of shell companies, nominee shareholders, or offshore entities without a clear commercial rationale;
● Requests to receive or make payments in jurisdictions unrelated to the client’s operations or service delivery;
● Transactions involving high-risk jurisdictions with weak AML/CFT controls, without legitimate economic justification;
● Transactions structured to avoid regulatory reporting or record-keeping thresholds;
● Payments routed through multiple intermediaries or unrelated entities;
● Unusual or disproportionate management fees, consulting fees, dividends, or profit distributions not supported by the financial performance or operational activities of the client.
12. Record Keeping
● customer identification documents;
● beneficial ownership information;
● screening results;
● transaction records;
● internal approvals;
● STR-related documentation; and
● compliance correspondence.
13. Training
14. Breaches and Disciplinary Action
15. Review of Policy
This AML/CFT Policy has been approved by the senior management of the Company and adopted as of the Effective Date. The Company commits to maintaining this Policy in accordance with applicable laws and regulations.