AML/KYC Policy
1. Purpose and Commitment
Montrock maintains a risk-based AML/CFT/CPF framework designed to prevent the Company, its accounts and its payment channels from being used for money laundering, terrorist financing, proliferation financing, sanctions evasion or related financial crime.
This public policy is a summary. Detailed detection rules, thresholds, internal reporting and suspicious-transaction procedures are confidential and are not published on the website.
2. Regulatory Framework
The framework is designed around applicable Mauritius legislation and FSC requirements, including the Financial Intelligence and Anti-Money Laundering Act, the Financial Intelligence and Anti-Money Laundering Regulations 2018, applicable FSC AML/CFT/CPF guidance, and sanctions and counter-proliferation obligations.
3. Governance
The Board retains ultimate oversight. The Compliance function and MLRO administer day-to-day controls, escalation, regulatory reporting, training and monitoring. Staff must cooperate with Compliance and must not override AML decisions without appropriate authority.
4. Business Risk Assessment
The Company assesses inherent and residual risks arising from client type, geography, products, services, delivery channels, payment methods, transaction profile, technology, counterparties and emerging threats. The assessment is reviewed periodically and when material changes occur.
5. Customer Due Diligence
Before establishing a relationship the Company obtains and verifies information sufficient to identify the customer and understand the purpose and intended nature of the relationship.
For individuals this may include identity, address, nationality, tax residence, occupation/business, expected activity, source of funds and source of wealth.
For legal entities this may include incorporation records, constitutional documents, registered office, principal place of business, directors, authorised persons, ownership and control, beneficial owners, nature of business, licences, expected activity and financial information.
6. Beneficial Ownership
The Company identifies and takes reasonable measures to verify natural persons who ultimately own or control a legal entity or arrangement. Complex structures may require additional corporate records, ownership charts, explanations and independent evidence.
7. PEPs
Politically Exposed Persons, their family members and close associates may be subject to enhanced due diligence, source-of-wealth/source-of-funds review, senior-management approval where required, and enhanced ongoing monitoring. PEP status does not automatically imply wrongdoing.
8. Enhanced Due Diligence
EDD may be applied where risk is higher, including high-risk jurisdictions, complex structures, unusually large transactions, high-risk industries, adverse media, unusual payment patterns, private investment vehicles, third-party funding or other identified risk factors.
9. Sanctions and Screening
Clients, beneficial owners, directors, authorised persons and relevant counterparties are screened against applicable sanctions and watchlists. Potential matches are escalated for review. The Company will not knowingly make funds or services available in breach of applicable sanctions.
10. Source of Funds and Source of Wealth
The Company may request documentary evidence demonstrating how specific funds were generated and how a client’s overall wealth was accumulated. Evidence may include financial statements, bank statements, sale agreements, tax records, payslips, audited accounts, investment records, inheritance documents or other credible material.
11. Transaction Monitoring
Accounts and transactions are monitored using risk-based controls designed to identify activity inconsistent with the known client profile or indicative of financial crime. Examples include unexplained increases in volume, third-party funding, rapid movement of funds, unusual geographic exposure, unexplained counterparties, structuring and transaction patterns without clear economic rationale.
12. Suspicious Activity
Employees must report concerns internally to the MLRO. The Company may make reports to competent authorities where required. The Company will not disclose information in a way that would amount to unlawful tipping off.
13. Record Keeping
CDD, screening, transaction and investigation records are retained for the periods required by applicable law and Company policy.
14. Training and Independent Review
Relevant staff receive periodic AML/CFT/CPF training. The effectiveness of the framework is subject to compliance monitoring and independent review/audit as required.
15. Refusal, Restriction and Termination
The Company may refuse onboarding, delay or reject transactions, restrict an account or terminate a relationship where due diligence is incomplete, risk is unacceptable or legal/regulatory obligations require action.
Contact and Regulatory Information
Montrock Ltd is incorporated in Mauritius under Company No. 231276 GBC and is regulated by the Financial Services Commission, Mauritius (FSC) as an Investment Dealer (Full Service Dealer, Excluding Underwriting), FSC Licence No. GB25205688. Registered office: Suite 201, Level 2, The Catalyst, 40 Silicon Avenue, Cybercity, Ebene 72201, Mauritius.
Compliance enquiries: compliance@mont-rock.com
Website: https://mont-rock.com
Risk warning: Transactions in financial instruments, particularly leveraged or derivative instruments where offered, involve significant risk and may result in substantial loss. Nothing on the website constitutes a guarantee of profit or investment performance.