Anti-Money Laundering (AML) Policy

This policy applies to all Vaulted personnel, contractors, introducers and to every prospective and existing client regardless of jurisdiction, industry or engagement size. It also governs onward disclosure of client files to our regulated partners for their own independent onboarding.

Vaulted operates a documented risk-based approach. Prospective clients are scored across geographic risk, industry risk, product risk, structure risk and delivery channel risk. Higher scores trigger Enhanced Due Diligence (EDD) and require senior sign-off before engagement.

Automatic EDD applies to, without limitation:

• Politically Exposed Persons (PEPs), their family members and close associates.
• Clients or beneficial owners resident in FATF high-risk or increased-monitoring jurisdictions.
• Complex ownership structures, bearer instruments or nominee arrangements outside Vaulted's own approved framework.
• Cash-intensive businesses, unlicensed money-service businesses, unlicensed gambling, arms and dual-use goods.
• Any file where source of funds or source of wealth cannot be plausibly evidenced.

Vaulted verifies, at a minimum:

• Identity of every individual owning or controlling 10% or more of a corporate applicant, and of every director and authorised signatory.
• Legal existence, good standing and ownership structure of every corporate entity in the chain up to the ultimate beneficial owner.
• Nature and purpose of the intended business relationship, expected activity, expected volume and expected counterparties.
• Source of funds for the transaction and source of wealth of the ultimate beneficial owner, supported by documentary evidence.

Identification is performed using government-issued photo identity documents, address verification (utility bill or bank statement dated within three months) and, where appropriate, notarised or apostilled certified copies. All onboarding records are retained for a minimum of five (5) years after the end of the relationship.

Every applicant, beneficial owner, director, shareholder and authorised signatory is screened against consolidated sanctions lists (UN, EU, UK HMT, US OFAC), against the official PEP databases and against adverse-media sources through licensed screening vendors. Screening is repeated on an ongoing basis for the duration of the relationship. A positive match blocks onboarding and, for existing clients, triggers immediate escalation to the Money Laundering Reporting Officer (MLRO).

Vaulted will not accept, and will terminate, any relationship connected to:

• Money laundering, terrorist financing or proliferation financing in any form.
• Sanctioned persons, entities or jurisdictions.
• Trade in narcotics, human trafficking, child exploitation material or wildlife trafficking.
• Trade in weapons, ammunition, military and dual-use goods without lawful authorisation.
• Unlicensed financial services, unlicensed gambling, unregistered securities offerings and Ponzi or pyramid schemes.
• Any activity that is illegal in the jurisdiction of operation, residence or destination of funds.

The privacy and discretion benefits described in our commercial materials refer exclusively to the legitimate protection of client information from public registers and unrelated third parties. They do not extend to concealment from competent authorities, regulated partners or Vaulted itself. Vaulted always knows the ultimate beneficial owner of every structure it services.

Client files are periodically reviewed against the stated activity profile. Material changes in ownership, control, industry, expected volume or counterparties trigger a fresh review. Vaulted also cooperates fully with monitoring and information requests raised by its regulated partners.

Any Vaulted employee who forms a suspicion of financial crime is required to escalate the matter internally to the MLRO without delay and without notifying the client (no-tipping-off rule). Where the MLRO concludes that suspicion is well-founded, a report is filed with the competent Financial Intelligence Unit and, where relevant, the transaction or relationship is suspended pending clearance.

All personnel receive AML, CTF and sanctions training on induction and at least annually thereafter. Overall responsibility for the AML programme rests with the MLRO, who reports directly to Vaulted management and is independent of commercial functions.

Identification data, transaction records, screening results and internal reports are retained in a secure, restricted environment for a minimum of five (5) years after the end of the business relationship, or longer where required by applicable law or by a partner institution.

For AML-related enquiries or lawful requests from competent authorities, contact the MLRO at compliance@vaulted.ae.