1. Purpose
Meridien International is fully committed to maintaining the highest standards of compliance in line with international anti-money laundering (AML), counter-terrorism financing (CTF), and sanctions regulations. We adhere strictly to applicable laws and best practices across all jurisdictions in which we operate, including but not limited to the EU Anti-Money Laundering Directives, the Financial Action Task Force (FATF) Recommendations, and relevant national legislation. This policy sets out the principles and procedures we follow to prevent the misuse of our services for illegal activities.
2. Scope
This policy applies to all directors, employees, contractors, agents, and clients of Meridien International and covers all business activities and jurisdictions where we operate. Compliance with this policy is mandatory and forms a core part of our operational and ethical framework.
3. Our Legal Responsibilities
As a regulated corporate services provider, Meridien International has a legal obligation to prevent its services from being used for money laundering, terrorist financing, or other criminal activities. We are required to:
- Identify and verify the identity of all clients and ultimate beneficial owners (UBOs).
- Understand the nature and purpose of the business relationship.
- Monitor activities on an ongoing basis to detect suspicious transactions or behaviors.
These responsibilities ensure we meet the highest standards of transparency and regulatory compliance.
4. Client Due Diligence (CDD)
Our AML framework incorporates comprehensive due diligence checks, which include:
- Identity verification of all clients and ultimate beneficial owners using reliable, independent sources.
- Assessments of the source of funds and source of wealth to confirm the legitimacy of assets involved.
- Sanctions and Politically Exposed Person (PEP) screening against all relevant global lists.
- Review of corporate structures, business models, and transactions to ensure legitimacy.
- Verification of the client’s activities and the transactions conducted through our services.
These checks are conducted both prior to onboarding and on an ongoing basis throughout the business relationship.
5. Risk Assessment
We apply a risk-based approach to AML and CTF compliance, acknowledging that some clients and transactions pose greater risks than others. Factors influencing risk categorization include:
- Client’s country of residence or operation, especially if it is a high-risk jurisdiction.
- Whether the client is a Politically Exposed Person (PEP).
- The sector in which the client operates, such as financial services, digital assets, or cash-intensive businesses.
- Complexity and transparency of ownership or control structures.
Clients are classified as low, medium, or high risk, with Enhanced Due Diligence (EDD) measures applied to medium and high-risk cases.
6. Enhanced Due Diligence (EDD)
EDD procedures are required for higher-risk clients or transactions and may include:
- Additional identity verification and background checks.
- Detailed proof of wealth and source of funds documentation.
- Third-party references or independent verification of client information.
- More frequent reviews and monitoring of client activity.
EDD is particularly important for clients linked to high-risk jurisdictions, PEPs, complex ownership structures, and vulnerable business sectors.
7. Ongoing Monitoring
Compliance is a continuous process. We conduct ongoing monitoring to ensure all client information remains current and transactions align with the client’s business profile. As part of this process, clients may be requested to provide updated documentation or explanations for unusual activities.
Where discrepancies, inconsistencies, or suspicious activities are detected, Meridien International reserves the right to file a Suspicious Transaction Report (STR) with the appropriate authorities and to terminate the business relationship without prior notice.
8. Sanctions and PEP Screening
Meridien International maintains robust screening protocols to identify individuals and entities subject to sanctions or classified as PEPs.
- We screen all clients before onboarding and on a regular basis against sanctions lists issued by the United Nations, European Union, United Kingdom, United States, and other relevant authorities.
- We apply enhanced scrutiny to PEPs due to their increased exposure to risks.
- Any clients subject to sanctions or embargoes are declined or immediately removed from our service.
9. Client Responsibilities
Clients are expected to fully cooperate with our AML and compliance processes by providing complete, accurate, and timely information upon request. Non-cooperation or provision of misleading information may result in delays, refusal of services, or termination of the client relationship.
10. Reporting Suspicious Activity
All employees have a duty to report any suspicious activities or concerns regarding money laundering, terrorist financing, fraud, or other illegal conduct. Reports must be escalated promptly to the designated compliance officer, who will evaluate the matter and, if necessary, file a Suspicious Activity Report (SAR) with regulatory authorities in accordance with legal obligations.
11. Record Keeping
We maintain comprehensive and secure records of client identification, due diligence procedures, risk assessments, ongoing monitoring activities, and reports submitted to authorities. These records are retained for the minimum legally required periods and are accessible for regulatory review and audit purposes.
12. Staff Training and Awareness
Meridien International provides ongoing AML and compliance training tailored to employee roles, including:
- Education on relevant laws, regulations, and internal policies.
- Techniques for detecting and reporting suspicious activity.
- Updates on emerging risks, typologies, and regulatory changes.
This ensures a vigilant and informed workforce dedicated to upholding compliance standards.
13. Cooperation with Authorities
We fully cooperate with regulators, law enforcement, and other agencies in AML and CTF investigations, supplying accurate and timely information to aid in the prevention and detection of financial crime.
14. Zero Tolerance Policy
Meridien International maintains a strict zero-tolerance approach towards money laundering, terrorist financing, tax evasion, or any misuse of our services for unlawful purposes. We reserve the right to decline or terminate any engagement where there is a risk of regulatory breach or reputational harm to our firm.
15. Non-Compliance and Consequences
Any breach of AML/CTF regulations by clients or staff is treated with utmost seriousness and may lead to:
- Immediate suspension or termination of the client relationship.
- Disciplinary actions for employees, including potential dismissal.
- Reporting to authorities, which may result in legal sanctions or prosecution.
