Financial Crime Prevention

Anti-Money Laundering & Counter-Terrorist Financing Policy

Aligned to UK MLR 2017, EU AMLD6, FATF Recommendations, OFSI / OFAC Sanctions Rules

Effective Date

November 2025

Version

1.0

Jurisdiction

United Kingdom

Company Details

Company: Caspivelo Commodities Ltd

Legal Form: Private Company Limited by Shares

Jurisdiction: United Kingdom

Registered Office:

71–75 Shelton Street
Covent Garden, London
WC2H 9JQ, UK

1. Policy Statement

Caspivelo Commodities Ltd is committed to preventing money laundering, terrorist financing, sanctions evasion, fraud, bribery, and illicit trade. The company maintains a risk-based compliance programme aligned to the UK Money Laundering Regulations 2017, EU AMLD6, and the FATF International Standards.

Important Notice

  • Caspivelo does not accept client money, deposits, pooled investment funds, or manage funds for third parties.
  • All trading and investment activities are conducted exclusively on the company's own account.

2. Business Activities Covered Under This Policy

Refined Fuel Trading

EN590 Automotive Diesel and Jet A-1 Aviation Fuel

Brazilian Sugar Export

Coordination of ICUMSA 45 / 150 / 600+ grades

Commodity Project Management

Structured oversight and execution frameworks

Proprietary Capital Trading

Forex, indices, commodities & digital asset markets

Cross-Currency Settlements

Operations conducted in the following currencies:

GBP

British Pound

EUR

Euro

USD

US Dollar

AED

UAE Dirham

3. Governance & Responsibility

AML Compliance Structure

Position Name Responsibility
Director & Ultimate Beneficial Owner Mr William Anthony Morris Final authority over AML/CTF controls
AML Compliance Officer (MLRO) Mr William Anthony Morris (interim) KYC, risk scoring, SAR reporting, sanctions checks

MLRO Contact for Reporting Concerns:

Contact MLRO

4. Customer and Counterparty Due Diligence (CDD)

Caspivelo conducts full KYC on all trade counterparties, vendors, suppliers, representatives, intermediaries, and financial institutions before engagement.

Corporate Counterparties

Required Documents:

  • Certificate of Incorporation
  • Shareholder & UBO register
  • Passport(s) of UBO(s)
  • Company address proof & operating office verification
  • Board resolution authorising signatory
  • Sanctions & PEP screening logs

Individual Counterparties

Required Documents:

  • Passport or national ID
  • Proof of residential address (≤ 90 days old)
  • Source-of-Funds declaration (if applicable)

5. Enhanced Due Diligence (EDD) Triggers

Enhanced Due Diligence is mandatory where any of the following conditions apply:

EDD Required When:

  • Jurisdiction is FATF High-Risk or sanctioned
  • Payment is made by third party not listed on the contract
  • Counterparty has no trading history or no verifiable business premises
  • Transaction amount exceeds £150,000 equivalent
  • Cryptographic asset wallets are used

EDD Measures Include:

Video Verification

Video verification call with Ultimate Beneficial Owner

Financial Documentation

Request of audited financials or tax filings

Supply Chain Verification

Proof of goods allocation, refinery/terminal supply, or mill documentation

6. Sanctions & PEP Screening

All counterparties are screened against the following sanctions lists and databases:

OFSI UK Sanctions List

Office of Financial Sanctions Implementation

EU Consolidated Sanctions List

European Union sanctions database

UN Security Council Sanctions

United Nations sanctions list

U.S. OFAC SDN/E.O. Lists

Office of Foreign Assets Control

Screening Frequency

Prior to onboarding
Prior to contract signature
Prior to each payment or shipment release

Zero Tolerance Policy

Any sanctions match = Immediate escalation to MLRO and NCA reporting

7. Transaction Monitoring & Currency Controls

Settlement Models by Currency

Currency Settlement Model
GBP UK Faster Payments / CHAPS
EUR SEPA / SWIFT
USD Correspondent Bank SWIFT
AED UAE Central Bank Regulated SWIFT / Local Clearing

Payment Processing Prohibitions

No payments will be processed in the following circumstances:

  • To or from high-risk jurisdictions (as defined by FATF)
  • Through cryptocurrency mixers or anonymisation services
  • Without fully documented commercial purpose
  • Through third-party unrelated bank accounts

8. Record Keeping & Retention

What We Retain

All contracts, invoices, shipment documents, payment records, and KYC files

Retention Period

Minimum of 6 years from final transaction close

Storage Security

Tamper-protected digital form (ISO 27001 compliant storage)

Compliance Note: Records are maintained in accordance with UK Money Laundering Regulations 2017 (Regulation 40) and may be subject to inspection by regulatory authorities.

9. Suspicious Activity Reporting (SAR) Procedure

Where suspicion of money laundering, terrorist financing, or sanctions evasion arises, the following procedure is implemented:

1

Internal Review by MLRO

Immediate escalation to Money Laundering Reporting Officer for assessment

2

SAR Filed to UK FIU / NCA

Suspicious Activity Report submitted to UK Financial Intelligence Unit via SAR Online Portal

3

Transaction Suspension

All transactions paused until feedback received from authorities

Anti-Tipping Off

No disclosure shall be made to the counterparty about the SAR filing or investigation ("tipping off" prohibition under UK law)

10. Policy Review

Regular Review Schedule

This policy will be reviewed annually by the Director/MLRO or upon any regulatory update.

Reviews will assess the effectiveness of controls, incorporate regulatory changes, and address emerging money laundering and terrorist financing risks.

Review Triggers

  • Annual scheduled review
  • Changes to UK Money Laundering Regulations or FATF standards
  • Material changes to business operations or jurisdictions
  • Regulatory guidance or enforcement actions in the sector
  • Identification of control weaknesses or compliance gaps

Policy Authorization

Signed and Approved By:

Mr William Anthony Morris

Chief Executive Officer & MLRO

Caspivelo Commodities Ltd

London, United Kingdom

Document Version

1.0

Effective Date

November 2025

Next Review

November 2026

Regulatory Alignment

UK Money Laundering Regulations 2017

Statutory Instrument 2017 No. 692 (as amended)

EU AMLD6

Sixth Anti-Money Laundering Directive (EU) 2018/1673

FATF Recommendations

Financial Action Task Force International Standards

OFSI / OFAC Sanctions

UK and US financial sanctions compliance requirements

Questions About This Policy?

For inquiries regarding our AML/CTF compliance programme, please contact our Money Laundering Reporting Officer (MLRO) through our contact page.

Contact MLRO