AML & KYC Policy

1. Overview

EuroFiducia is committed to preventing money laundering, terrorist financing, and financial crime. We comply with the EU Anti-Money Laundering Directives (AMLD5, Directive 2018/843 and AMLD6, Directive 2018/1673), the French Monetary and Financial Code (Code monétaire et financier), and Italian Legislative Decree 231/2007 as amended.

2. Know Your Customer (KYC)

Before activating your account, we are required to verify your identity. Our KYC process includes:

• Identity verification — Full name, date of birth, nationality, and a valid government-issued photo ID (passport, national ID card, or driving licence for EU residents).
• Address verification — Proof of residential address (utility bill, bank statement, or official document dated within the last 3 months).
• Tax identification — Your tax identification number (numéro fiscal in France, codice fiscale in Italy) for reporting and compliance purposes.
• Source of funds — Information about the origin of funds you intend to invest.

3. Customer Due Diligence (CDD)

We apply risk-based customer due diligence to all clients:

• Simplified due diligence — For low-risk clients and certain regulated products.
• Standard due diligence — Identity and address verification, source of funds confirmation.
• Enhanced due diligence (EDD) — For high-risk clients, including PEPs (Politically Exposed Persons), clients from high-risk jurisdictions, or complex/large transactions. EDD requires senior management approval and additional documentation.

4. Politically Exposed Persons (PEP)

During registration, you are required to declare whether you are a PEP, a family member of a PEP, or a known close associate of a PEP. PEPs are individuals who hold or have held prominent public functions. If you are a PEP, we will apply enhanced due diligence and obtain senior management approval before establishing the business relationship.

5. Sanctions Screening

We screen all clients against EU, UN, OFAC, and national sanctions lists at onboarding and on an ongoing basis. Accounts matching sanctions lists will be blocked and reported to the relevant authorities. We also screen against lists of known terrorists and financial criminals.

6. Transaction Monitoring

We monitor transactions for suspicious activity using automated and manual processes. Red flags include:

• Unusual transaction patterns inconsistent with the client's profile
• Large or frequent cash deposits without clear economic purpose
• Structuring transactions to avoid reporting thresholds
• Transfers to or from high-risk jurisdictions
• Sudden changes in investment behavior inconsistent with the client's stated objectives

Suspicious transactions are investigated by our compliance team and, where appropriate, reported to TRACFIN (France) or UIF (Unità di Informazione Finanziaria, Italy) — the national financial intelligence units.

7. Reporting Obligations

Under AML regulations, we are required to report suspicious activities to the relevant financial intelligence unit. Such reports are confidential, and we are prohibited from informing clients that a report has been made (this is known as "tipping off" and is a criminal offense).

8. Record Keeping

We retain KYC documentation, transaction records, and compliance documentation for a minimum of 5 years after the end of the business relationship, in accordance with AMLD5. Certain records may be retained longer where required by other regulatory or tax obligations.

9. Client Obligations

As a client, you agree to:

• Provide accurate, complete, and truthful information during onboarding and ongoing
• Inform us of any changes to your personal details, address, or tax status
• Cooperate with any additional verification requests
• Not use the Platform for money laundering, terrorist financing, or any unlawful purpose
• Understand that we may delay or refuse transactions that trigger compliance concerns

10. Consequences of Non-Compliance

If we cannot verify your identity, or if we identify suspicious activity, we may:

• Delay or refuse to execute transactions
• Suspend or close your account
• Report to the relevant financial intelligence unit
• Cooperate fully with regulatory and law enforcement authorities

11. Training & Governance

All EuroFiducia employees receive regular AML/KYC training. Our compliance program is overseen by a designated Money Laundering Reporting Officer (MLRO) and reviewed by senior management and external auditors.

12. Contact

For AML/KYC questions, contact our Compliance Department at [email protected] or through your dashboard support center.

EuroFiducia SAS · AMLD5/AMLD6 Compliant · TRACFIN/UIF registered