Anti-Money Laundering & Counter-Terrorist Financing Policy
Our AML/CTF standards, customer due diligence and reporting expectations.
SBank is committed to full compliance with all applicable UK legislation and regulatory requirements, including without limitation:
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended) ("MLR 2017");
- Proceeds of Crime Act 2002 ("POCA");
- Terrorism Act 2000 and Counter-Terrorism Act 2008;
- Sanctions and Anti-Money Laundering Act 2018 and applicable UK sanctions regimes; and
- Relevant rules and guidance issued by the Financial Conduct Authority ("FCA") and other competent UK authorities.
1. Scope and application
This AML/CTF Policy applies to all activities of SBank, including the onboarding of customers, the provision of payment and account services, the processing of transactions and the ongoing monitoring of customer relationships. It applies to all categories of customers (including individuals, legal entities and other arrangements), to all delivery channels (including remote / digital onboarding) and to all jurisdictions in which we operate or from which we service clients.
The Policy is binding on all directors, officers, employees, contractors and other persons engaged by or acting on behalf of SBank. Failure to follow this Policy may result in internal disciplinary action and, where appropriate, reporting to competent authorities.
2. Governance and oversight
The Board and senior management of SBank bear ultimate responsibility for establishing and maintaining an effective AML/CTF framework. They set the risk appetite, approve this Policy and receive regular reports on the effectiveness of the controls described here.
SBank designates an appropriately qualified Money Laundering Reporting Officer ("MLRO") and, where appropriate, a deputy MLRO. The MLRO has direct access to senior management and is responsible for:
- overseeing the implementation and ongoing operation of the AML/CTF framework;
- acting as the central point of contact for competent authorities in AML/CTF matters;
- receiving, investigating and, where appropriate, escalating internal suspicious activity reports;
- ensuring that adequate AML/CTF training is provided to relevant staff; and
- providing regular management information on AML/CTF risks, incidents and remediation activities.
3. Risk-based approach
SBank applies a documented, risk-based approach to AML/CTF in line with MLR 2017 and FCA expectations. We identify, assess and document the money laundering and terrorist financing risks arising from our customers, products, services, delivery channels and geographic exposure. These assessments are reviewed periodically and whenever there is a material change in our business model, regulatory environment or risk profile.
Controls are proportionate to the level of risk identified. Higher-risk situations result in enhanced measures, while lower-risk situations may attract simplified due diligence where permitted by law. No risk is ever considered "zero" and basic due diligence requirements always apply.
4. Customer due diligence (CDD)
We perform customer due diligence before establishing a business relationship or carrying out an occasional transaction that meets relevant thresholds. CDD measures include, at a minimum:
- identifying the customer and verifying the customer's identity using reliable, independent sources;
- where the customer is a legal person or arrangement, identifying and verifying its beneficial owners to the extent required by law;
- understanding the nature and intended purpose of the business relationship (for example, anticipated activity, source of funds, expected volumes, and countries of origin/destination); and
- conducting ongoing monitoring of the relationship and transactions to ensure consistency with the customer's risk profile.
For remote onboarding, SBank may use electronic identification and verification tools and trusted third‑party providers. Where such tools are used, we ensure that they are reliable and compliant with applicable UK law and supervisory guidance.
5. Enhanced due diligence (EDD)
Where a customer, product, service or transaction presents a higher risk of money laundering, terrorist financing or other financial crime, SBank applies enhanced due diligence. Situations which may warrant EDD include, without limitation:
- customers or beneficial owners who are Politically Exposed Persons ("PEPs") or close associates of PEPs;
- customers with complex or opaque ownership and control structures without an obvious legitimate purpose;
- transactions involving high‑risk jurisdictions identified by the UK authorities, the Financial Action Task Force (FATF) or other competent bodies;
- unusually large, complex or non‑standard transactions that have no apparent economic or lawful purpose; and
- any relationship where adverse media or other information indicates an increased risk.
EDD measures may include:
- obtaining additional information on the customer, beneficial owners and source of funds / wealth;
- more frequent and more detailed ongoing monitoring of transactions and account behaviour;
- senior management approval before establishing or continuing the relationship; and
- restricting or refusing certain products, services or transaction types.
6. Source of funds and source of wealth
To mitigate the risk that our services could be used to introduce illicit assets into the financial system, SBank may request information and documentation regarding the customer's source of funds and, where appropriate, source of wealth. Customers are expected to cooperate with such requests promptly and fully.
Acceptable evidence may include, for example, salary slips, tax returns, bank statements, sale and purchase agreements, loan agreements, audited financial statements or other documents that, in our reasonable opinion, are sufficient to demonstrate the lawful origin of funds. Where adequate information or documentation is not provided, we may decline or terminate the relationship and, where appropriate, file a report with the competent authority.
7. Screening and sanctions
SBank screens customers and, where appropriate, related parties against relevant sanctions lists and other watchlists before and during the business relationship. This may include, for example, UK sanctions lists, UN sanctions lists and other lists that SBank considers relevant in light of its risk appetite and legal obligations.
Where a match or potential match is identified, the MLRO or delegated staff review the case without undue delay, apply appropriate account restrictions and, where required, report to the competent authority. SBank complies with asset‑freezing and other restrictive measures as required under applicable sanctions legislation.
8. Transaction monitoring
We operate risk‑sensitive, automated and manual transaction monitoring to identify unusual or suspicious activity. Monitoring parameters and scenarios are defined having regard to the specific risks associated with our customer base and product offering and are subject to periodic review.
Alerts generated by the monitoring systems are investigated in a timely manner by appropriately trained staff. Where an alert cannot be reasonably explained by the known profile and legitimate activities of the customer, further escalation may occur, including the filing of an internal suspicious activity report.
9. Suspicious activity reporting
All staff of SBank are required to remain vigilant for indicators of money laundering, terrorist financing and other financial crime and to escalate any suspicions to the MLRO or their delegate without delay. Internal reports must contain all relevant facts and be supported by available documentation where possible.
The MLRO (or delegate) evaluates internal reports and determines whether the suspicion meets the legal threshold for reporting to the competent authority in the United Kingdom. Where appropriate, reports are submitted in the prescribed form and manner. Staff must not, under any circumstances, engage in "tipping off" or otherwise inform the customer or third parties that a report has been or may be made.
10. Freezing, blocking and refusal of transactions
SBank reserves the right to delay, block or refuse to process transactions, or to place restrictions on accounts, where necessary to comply with AML/CTF or sanctions obligations, or where we reasonably suspect that a transaction may be linked to unlawful activity. In some instances, we may be legally prevented from informing the customer of the specific reason for such measures.
We may also terminate a business relationship where the AML/CTF risk is no longer acceptable in light of our risk appetite or where the customer fails to provide accurate, complete and timely information required for due diligence or ongoing monitoring.
11. Record keeping
SBank keeps records of customer due diligence, account information, transaction data, suspicious activity reports and other relevant documentation for at least the minimum periods required by UK law, and longer where necessary to comply with legal, regulatory or contractual obligations.
Records are maintained in a secure and accessible manner, sufficient to enable SBank to respond to lawful information requests from competent authorities and to demonstrate the adequacy and effectiveness of its AML/CTF controls.
12. Training and awareness
Appropriate AML/CTF training is provided to employees and other relevant personnel at the commencement of their engagement and periodically thereafter. Training content is tailored to the role and responsibilities of participants and covers, at a minimum, relevant legal and regulatory obligations, internal policies and procedures, indicators of suspicious activity and reporting channels.
Attendance at mandatory training is monitored and follow‑up action is taken where participation is incomplete or unsatisfactory.
13. Cooperation with authorities
SBank cooperates fully and promptly with competent UK and, where lawful, foreign authorities in the prevention and detection of money laundering and terrorist financing. This may include, for example, responding to information requests, production orders, freezing orders and other lawful measures. All such cooperation takes place in accordance with applicable data protection, confidentiality and banking secrecy requirements.
14. Review of this Policy
This AML/CTF Policy is reviewed at least annually and whenever there is a material change in legal or regulatory requirements, supervisory expectations or the nature of SBank's activities. Updates may be made more frequently where necessary to maintain an effective and proportionate AML/CTF framework.
The latest version of this Policy is made available on our website and may also be provided to customers on request. If you have questions about this Policy, please contact our support team at support@s-bank.online.
Last updated: 19 January 2026