AML and CTF Policy

1. Policy scope and governance

This policy applies to TKB’s employees, officers, and other representatives. They must follow current law and TKB’s approved policies and procedures.

The Chief Compliance Officer reviews the policy periodically. Management is responsible for making approved policies and amendments available to relevant representatives. The framework is based on the laws and regulatory requirements applicable to TKB in the Commonwealth of Dominica and takes account of relevant international AML, CTF, and proliferation-financing standards.

2. Money laundering, terrorism financing, and proliferation financing

Money laundering includes converting, transferring, concealing, disguising, acquiring, possessing, or using property while knowing that it derives from criminal conduct. It commonly involves placement of illicit funds, layering transactions to obscure their origin or ownership, and integration into the legitimate economy.

Terrorism financing includes unlawfully providing or collecting funds, directly or indirectly, with the intention or knowledge that they will be used for terrorist acts. Funds may come from criminal activity or legitimate sources, and an offence may arise even where the funds are not ultimately used.

Proliferation financing includes providing funds or financial services connected with weapons of mass destruction, their means of delivery, or related materials in breach of applicable law.

• Placement introduces proceeds of crime into the financial system.
• Layering uses transactions or changes in ownership or asset form to conceal source or control.
• Integration returns funds to the economy with an appearance of legitimacy.

3. Risk-based approach

TKB assesses and manages financial-crime risk using a risk-based approach. Higher-risk circumstances receive enhanced controls and attention. Assessments are reviewed as risks, services, regulation, and operating conditions change.

• Customer type, ownership, activity, and expected account use.
• Products and designated services provided.
• Delivery channels and transaction methods.
• Countries and jurisdictions connected with a customer or transaction.
• Organisational structure, staffing, and control effectiveness.

4. AML and CTF programme

TKB maintains an AML and CTF programme designed to identify, mitigate, and manage financial-crime risk. It covers governance, customer due diligence, enhanced due diligence, sanctions and screening controls, transaction monitoring, reporting, record keeping, training, and independent review.

Controls are proportionate to assessed risk and may require TKB to delay, restrict, decline, freeze, or end a relationship or transaction where required or permitted by law and contract. TKB does not disclose confidential reporting or investigative activity where disclosure is prohibited.

5. Customer due diligence

TKB identifies and verifies customers and, where applicable, beneficial owners, controllers, authorised persons, and representatives. TKB also seeks to understand the purpose and intended nature of a relationship, source of funds or wealth where relevant, and expected activity.

Due diligence must be completed to the extent and at the time required by law and TKB procedures. If satisfactory information or evidence is not provided, TKB may be unable to open or maintain an account or execute a transaction.

• Identity, date and place of birth or incorporation, nationality or jurisdiction, and address.
• Occupation, business activity, ownership, control, and contact information.
• Purpose of the relationship, expected activity, source of funds, and source of wealth when required.
• Supporting documents and independent or reliable verification data.

6. Enhanced due diligence and politically exposed persons

Enhanced due diligence may apply to higher-risk customers, beneficial owners, jurisdictions, products, delivery channels, or transactions. It may include additional evidence, senior approval, closer monitoring, and more frequent review.

Politically exposed persons, their family members, and close associates are subject to identification and risk controls required by applicable law. PEP status does not by itself imply criminal activity, but it may require enhanced assessment and monitoring.

7. Correspondent banking and intermediaries

Before establishing relevant correspondent or intermediary relationships, TKB assesses the institution’s business, ownership, reputation, supervision, AML and CTF controls, and the nature of services to be provided. Required approvals and documented responsibilities must be in place.

TKB does not knowingly establish relationships with shell banks and takes reasonable measures to avoid relationships that permit shell-bank access. Payable-through, nested, gateway, trust, and other intermediary arrangements receive controls proportionate to their risk.

8. Sanctions, adverse information, and screening

TKB applies screening and investigation controls appropriate to its legal obligations and risk exposure. These may include checks concerning sanctions, terrorism designations, proliferation, politically exposed persons, adverse information, and internal restrictions.

Potential matches are reviewed before action is taken. TKB may reject, suspend, freeze, report, or otherwise restrict activity when required or permitted by applicable law.

9. Employee due diligence and training

TKB applies risk-appropriate screening and oversight to employees and relevant representatives. Personnel receive AML and CTF awareness and role-specific training, including escalation duties, suspicious-activity indicators, confidentiality, and record keeping.

Training is refreshed periodically and when material legal, risk, product, or procedural changes occur.

10. Ongoing monitoring and reassessment

TKB monitors customer relationships and transactions to determine whether activity is consistent with its knowledge of the customer, business, risk profile, and source of funds where necessary. Customer records and risk assessments are refreshed at intervals or following relevant trigger events.

Monitoring may consider unusual size, pattern, frequency, counterparties, jurisdictions, rapid movement of funds, structuring, electronic transfers, trusts, intermediaries, and activity without an apparent lawful or economic purpose.

11. Suspicious activity and regulatory reporting

Employees and representatives must promptly escalate knowledge, suspicion, or reasonable grounds for suspicion through TKB’s internal reporting process. The authorised compliance function determines whether a report or other action is required.

TKB makes suspicious-transaction, terrorism-property, threshold, sanctions, and other reports to competent authorities when required. A transaction may be reported whether completed, attempted, delayed, declined, or cancelled.

12. Confidentiality and prohibition on tipping off

Information about an internal or external suspicious-activity report, investigation, or related authority request is restricted and protected. Personnel must not disclose information where doing so could prejudice an investigation or amount to prohibited tipping off.

Customer privacy and confidentiality remain subject to disclosures required or permitted by law, regulation, court order, regulatory request, and TKB’s applicable privacy terms.

13. Record keeping

TKB retains customer-identification, due-diligence, account, transaction, monitoring, training, review, and reporting records for the period required by applicable law and approved retention schedules. The legacy policy states a minimum period of seven years after the relevant transaction or relationship ends, subject to longer retention where law, an investigation, legal hold, or authority requires it.

Records must be sufficient to reconstruct relevant transactions and must be retrievable within a reasonable period for authorised review or lawful requests.

14. Compliance responsibility and authority

The designated AML and CTF compliance function has authority, independence, access to relevant records and personnel, and responsibility for administering the programme, receiving internal reports, advising the business, coordinating reporting, and monitoring remediation.

Business functions remain responsible for operating their controls and promptly escalating concerns.

15. Independent review and control testing

TKB arranges periodic, risk-based independent review or testing of its AML and CTF programme, processes, systems, and controls. Findings are documented, reported to appropriate governance bodies, and tracked to resolution.

The scope and frequency of review reflect regulatory requirements, risk, material changes, and previous findings.

16. Cooperation with competent authorities

TKB cooperates with the Financial Services Unit, Financial Intelligence Unit, law-enforcement bodies, courts, and other competent authorities as required by applicable law. This may include producing information or documents, supporting lawful examinations, and implementing directions or restrictions.

Authority feedback and regulatory developments are considered in programme updates where relevant.

17. Protection for good-faith reporting

TKB supports lawful, good-faith internal and external reporting. Information about a person who makes or contributes to a protected report is handled according to applicable confidentiality and legal-protection requirements.

Nothing in this public policy changes any statutory protection, immunity, duty, offence, or reporting threshold.

18. Illustrative risk indicators

No single indicator necessarily establishes financial crime. Indicators are assessed together with customer context, lawful explanations, documentary evidence, and other available information.

• Structuring or splitting activity to avoid identification, monitoring, or reporting controls.
• Electronic transfers, rapid pass-through activity, or complex routing without a clear lawful purpose.
• Trust, company, nominee, or intermediary arrangements that obscure beneficial ownership or control.
• Activity inconsistent with the stated business, expected profile, known income, source of funds, or source of wealth.
• Connections to high-risk jurisdictions, sanctions, terrorism, proliferation, serious crime, or materially adverse information.

19. Legal and regulatory framework

TKB’s controls are intended to comply with the AML, counter-terrorism-financing, proceeds-of-crime, sanctions, banking, and related requirements applicable to its licensed activities in the Commonwealth of Dominica. The precise legal framework and authority names may change and must be verified against current official sources.

This summary is informational and does not reproduce every statutory definition, offence, power, exemption, or procedure. It does not provide legal advice and does not create rights beyond applicable law or contract.

20. Policy review

TKB reviews this policy and its internal programme periodically and when material legal, regulatory, business, product, risk, or control changes occur. The current approved English policy and applicable law remain authoritative pending formal approval of any translation.