AML / CFT

​

Regulatory status

Under Malta’s Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR), the Company does not qualify as a “subject person” — it does not carry out any “relevant financial business” or “relevant activity” under the meaning of those regulations. It is therefore not subject to the obligations imposed by AML/CFT legislation in this jurisdiction.

​

Voluntary controls

Notwithstanding the above, the Company implements the following risk-mitigation measures:

• Investor due diligence. Documentation and screening on investors participating in private sales.
• Counterparty screening. A policy of declining to deal with third parties that present, on the available evidence, a high risk of money laundering or terrorism financing.

These controls are voluntary and do not constitute a formal AML/CFT compliance program of a regulated entity.

​

Reference

• PMLFTR — Subsidiary Legislation 373.01 (official Maltese legislation portal).
• For full whitepaper terms see Legal Information and the Disclaimer.