Fiducia Clearing Limited (“Fiducia Clearing,” “we,” “us” or “our”) is committed to conducting its activities in accordance with applicable anti-money laundering, counter-terrorist financing, sanctions and financial-crime laws and regulations.
This Anti-Money Laundering Notice (“AML Notice”) provides a general description of the compliance measures that may apply when a person or organization seeks access to a product or service described by Fiducia Clearing.
This AML Notice is informational only. It does not describe every control, procedure or legal obligation and does not form a customer agreement.
1. Scope
Compliance reviews may be performed by Fiducia Clearing or by a banking, payment or digital-asset provider regulated where required, or an identity-verification or other service provider involved in providing or evaluating a requested service.
The checks and information required may differ depending on the applicant, product, jurisdiction, ownership structure, transaction type and risk profile.
2. Identity and business verification
Before providing or facilitating access to a service, Fiducia Clearing or a relevant service provider may request information and documents to identify and verify:
- an individual applicant;
- a business or other legal entity;
- directors, officers and authorized representatives;
- beneficial owners and persons exercising control;
- the nature and purpose of the business relationship; and
- the expected type, volume and geographic scope of activity.
Information may be checked against documents, public records, commercial databases and other lawful sources.
Applicants must provide accurate, complete and current information and promptly notify us of material changes.
3. Beneficial ownership and control
Business applicants may be required to disclose their direct and indirect ownership and control structure, including the identity of ultimate beneficial owners and controlling persons.
Additional information may be requested where an ownership structure is complex, involves trusts, nominees, intermediaries or multiple jurisdictions, or otherwise requires enhanced review.
We may be unable to proceed where ownership or control cannot be reasonably established or verified.
4. Sanctions and screening
Applicants, customers, beneficial owners, controllers, representatives, counterparties, beneficiaries and transactions may be screened against applicable sanctions, restricted-party, politically exposed person and adverse-information sources.
Screening may occur during onboarding and periodically thereafter. A potential match may require additional information, delay a review or transaction, or result in restriction or refusal where required or permitted by law.
Fiducia Clearing will not knowingly provide or facilitate services prohibited by applicable sanctions laws.
5. Source of funds and source of wealth
Where appropriate, applicants or customers may be asked to explain and document the source of funds, source of wealth, purpose of a transaction or economic rationale for anticipated activity.
Supporting information may include business records, financial statements, bank records, contracts, invoices, tax records or other relevant evidence.
Failure to provide satisfactory information may prevent or delay access to a service.
6. Ongoing review and transaction monitoring
Where a service is provided, activity may be reviewed or monitored on a risk-sensitive basis to identify conduct that appears inconsistent with the known customer profile, expected activity, applicable law or the terms governing the service.
We or a relevant service provider may request additional information about a payment, transfer, conversion, counterparty, wallet, beneficiary or source and destination of funds.
The fact that a transaction is delayed or reviewed does not necessarily mean that unlawful activity has occurred.
7. Requests for additional information
Applicants and customers must cooperate with reasonable compliance and information requests.
If requested information is not provided within the required period, Fiducia Clearing or the responsible service provider may, where permitted by law:
- pause or decline an application;
- delay, reject or restrict a transaction;
- limit, suspend or terminate access to a service; or
- take other action reasonably necessary to comply with legal or regulatory obligations.
We may not always be permitted to explain the reason for a compliance action.
8. Prohibited activity
The Website and any related service must not be used to facilitate:
- money laundering or concealment of criminal proceeds;
- terrorist financing;
- fraud, theft, bribery, corruption or tax evasion;
- sanctions evasion or dealings with prohibited persons or jurisdictions;
- trafficking, exploitation or other serious criminal activity;
- transactions intended to avoid reporting, verification or recordkeeping requirements;
- use of false identities, nominee arrangements or misleading ownership information; or
- any activity prohibited by applicable law or a separate service agreement.
This list is illustrative and not exhaustive.
9. Regulatory and law-enforcement disclosures
Fiducia Clearing and relevant service providers may retain and disclose information to regulators, law-enforcement agencies, courts, government authorities and other authorized recipients where required or permitted by law.
Where required by applicable law, suspicious activity will be reported to the appropriate authority; it may also be reported where permitted by law. Laws relating to suspicious activity reports may prohibit us from confirming whether a report has been considered, prepared or filed. We will not provide information that we are legally prohibited from disclosing.
10. Records
Information and records relating to identity verification, business verification, transactions, compliance reviews and regulatory reports may be retained for the period required by applicable law, regulatory obligations, service-provider requirements and legitimate legal or compliance needs.
These retention periods may continue after an application is declined or a customer relationship ends.
11. Third-party service providers
Some accounts, payments, conversions, custody, settlement or compliance functions may be provided or performed by third parties under separate agreements.
Those providers may conduct their own verification, screening, monitoring and reporting and may apply standards or restrictions in addition to those described in this AML Notice.
Use of a third-party provider does not relieve Fiducia Clearing of any legal or regulatory obligation that applies directly to it.
Fiducia Clearing cannot override a third party’s independent legal or regulatory obligations.
12. No guarantee of approval or processing
Completion of verification does not guarantee approval, continued access to a service or execution of a transaction.
Eligibility and availability remain subject to applicable law, risk assessment, compliance review, service-provider requirements and separate written agreements.
13. Changes to this AML Notice
We may update this AML Notice to reflect changes in law, regulation, products, service providers or compliance practices. The updated version will be posted with a revised “Last Updated” date.
14. Contact
General questions about this AML Notice may be sent to:
Fiducia Clearing Limited 30 N Gould St Ste R Sheridan, WY 82801 United States
Email: support@fiduciaclearing.com
For security reasons, we do not disclose confidential monitoring methods, risk thresholds, investigation procedures or suspicious-activity reporting decisions.