AML/CTF Policy

Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF) & Sanctions Limitation Policy

Effective: January 1, 2026 Version 1.0.0

Legal Disclaimer: This document is subject to legal counsel review. Please read carefully as it contains important information about your rights and obligations.

ANTI-MONEY LAUNDERING (AML), COUNTER-TERRORIST FINANCING (CTF) & SANCTIONS LIMITATION POLICY

Effective Date: 01 January 2026

1. PURPOSE OF THIS POLICY

This Anti-Money Laundering ("AML"), Counter-Terrorist Financing ("CTF"), and Sanctions Limitation Policy ("Policy") sets out the framework adopted by Confidiance Bank ("Confidiance Bank", "the Bank") to prevent, detect, deter, and report activities related to:

  • Money laundering
  • Terrorist financing
  • Proliferation financing
  • Sanctions breaches
  • Financial crime and misuse of financial systems

This Policy applies to all members, accounts, transactions, products, and services, including IBAN-linked accounts, treasury services, credit, insurance, and crypto-related products.

2. OPERATING & COMPLIANCE STRUCTURE

2.1 Confidiance Bank operates as a membership-based digital banking and treasury platform and does not itself act as an Electronic Money Institution ("EMI").

2.2 All IBAN accounts available through the Confidiance Bank platform are issued and regulated by third-party EMIs, primarily Valens Pay, together with their correspondent banking institutions.

2.3 Confidiance Bank maintains a Treasury Office in the United Kingdom, which coordinates treasury oversight, settlement administration, and compliance liaison.

2.4 Certain services may reference or interface with affiliated entities, including Regnum Group, strictly for operational and platform support purposes.

3. REGULATORY & LEGAL FRAMEWORK

This Policy is aligned with internationally recognised standards, including:

  • Financial Action Task Force (FATF) Recommendations
  • Applicable US AML and sanctions laws
  • European AML Directives and data protection standards
  • South African AML and financial crime principles
  • EMI regulatory obligations applicable to Valens Pay

Where conflicts arise, the highest applicable compliance standard shall apply.

4. MEMBER DUE DILIGENCE (KYC & KYB)

4.1 All Members are subject to Know Your Customer (KYC) or Know Your Business (KYB) procedures.

4.2 Confidiance Bank and/or its service providers may require:

  • Identity verification
  • Proof of address
  • Source of funds and source of wealth information
  • Corporate ownership and control documentation
  • Ongoing transaction profiling

4.3 Failure or refusal to provide required information may result in:

  • Account limitation
  • Transaction rejection
  • Account freeze
  • Termination of membership

5. ONGOING MONITORING & TRANSACTION REVIEW

5.1 All accounts and transactions are subject to continuous monitoring, including:

  • Automated screening
  • Manual review
  • Risk-based transaction analysis

5.2 Transactions may be flagged as:

  • Unusual
  • High-risk
  • Suspicious
  • Sanctions-related

5.3 Confidiance Bank reserves the right to delay, suspend, reverse, or block transactions pending review.

6. SANCTIONS SCREENING & LIMITATIONS

6.1 All Members, counterparties, and transactions are screened against applicable sanctions lists, including but not limited to:

  • US sanctions regimes
  • EU restrictive measures
  • UK sanctions frameworks
  • Other internationally recognised sanctions authorities

6.2 Accounts, IBANs, or transactions may be restricted or frozen where:

  • A sanctions risk is identified
  • A counterparty is located in or linked to a restricted jurisdiction
  • Enhanced due diligence is required

6.3 The Member acknowledges that:

  • Sanctions-related limitations do not constitute grounds for litigation
  • Confidiance Bank is not required to disclose the basis of sanctions flags where prohibited by law or compliance obligations

7. ACCOUNT FREEZES, HOLDS & INVESTIGATIONS

7.1 Confidiance Bank may, at its sole discretion:

  • Freeze or hold member accounts or IBANs
  • Restrict withdrawals or transfers
  • Conduct internal or external investigations

7.2 Investigations may involve:

  • EMI partners
  • Correspondent banks
  • Compliance consultants
  • Insurers
  • Auditors
  • Competent authorities where legally required

7.3 All compliance actions are final and binding, subject only to applicable law.

8. REPORTING & DISCLOSURES

8.1 Where required by law or regulation, Confidiance Bank and/or its service providers may:

  • File suspicious transaction or activity reports
  • Provide information to regulators or law enforcement agencies

8.2 The Member expressly agrees that:

  • No notification may be given where "tipping-off" is prohibited
  • Confidentiality obligations may be overridden by legal compulsion

9. DATA SHARING & CONFIDENTIALITY

9.1 By using the platform, the Member authorises Confidiance Bank to share relevant data with:

  • EMI providers
  • Banking partners
  • Compliance and screening providers
  • Insurance, credit, and crypto service providers

9.2 No information will be shared with third parties unless:

  • Required under a commercial agreement
  • Required by applicable law
  • Approved and validated internally by Confidiance Bank

10. HIGH-RISK ACTIVITIES & PROHIBITED USE

10.1 Confidiance Bank may restrict or prohibit activities deemed high-risk, including but not limited to:

  • Unlicensed financial services
  • Prohibited gambling or gaming activities
  • Sanctions-related trade
  • Terrorism-related activities
  • Fraudulent, deceptive, or abusive conduct

10.2 Determination of risk classification is at the sole discretion of Confidiance Bank.

11. TERMINATION & RISK EXIT

11.1 Confidiance Bank reserves the unrestricted right to:

  • Exit relationships
  • Terminate membership
  • Close or suspend accounts

11.2 Termination may occur without notice, and without requirement for acknowledgment by the Member.

12. LIMITATION OF LIABILITY

12.1 Confidiance Bank, its directors, shareholders, officers, and representatives shall not be liable for:

  • Losses arising from AML, CTF, or sanctions actions
  • Account freezes or transaction delays
  • Regulatory or EMI-mandated restrictions
  • Compliance-driven reporting or disclosures

13. CONTACT INFORMATION

14. GOVERNING STANDARDS

This Policy adheres to applicable US laws, European laws, and South African laws, particularly in relation to:

  • Financial crime prevention
  • Sanctions enforcement
  • Data protection and privacy

15. FINAL PROVISIONS

15.1 This Policy forms an integral part of Confidiance Bank's membership framework.

15.2 Confidiance Bank reserves the right to amend this Policy at any time. Continued use of the platform constitutes acceptance of any updates.

Document Version: 1.0.0 | Last Updated: January 1, 2026

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