1.  Introduction

Analie Sàrl (“Analie”, “we”, “us” or “our”) is committed to preventing money laundering, terrorist financing, and other financial crime.

We comply with all applicable Luxembourg laws and regulations, including:

  • The Law of 12 November 2004 on the fight against money laundering and terrorist financing (as amended)

  • Relevant EU Directives (including the 5th and 6th AML Directives)

We apply a risk-based approach to identify, assess, and mitigate risks associated with our clients and services.

2.  Scope

This policy applies to:

  • All services provided by us

  • All clients (individuals and entities)

  • All partners, employees, and contractors

3.  Risk-Based Approach

We assess AML risk based on:

  • Client risk (e.g. ownership structure, industry, PEP status)

  • Geographical risk (e.g. high-risk or sanctioned jurisdictions)

  • Service risk (e.g. complexity, cross-border elements)

  • Transaction risk

  • Enhanced due diligence is applied where higher risks are identified.

4.  Customer Due Diligence (CDD)

We perform customer due diligence:

  • Before establishing a business relationship

  • When required by law or where suspicion arises

  • When information previously obtained is no longer adequate

CDD measures include:

4.1 Identification and Verification

  • Individuals: identity verification using reliable and independent documents

  • Legal entities: verification of legal existence, structure, and ownership

4.2 Beneficial Ownership

We identify and verify the ultimate beneficial owner(s) (typically individuals holding 25% or more ownership or control).

4.3 Source of Funds and Wealth

Where appropriate, we obtain information on:

  • Source of funds

  • Source of wealth

4.4 Ongoing Monitoring

We conduct ongoing monitoring of:

  • Client relationships

  • Transactions

  • Risk profiles

Screening for sanctions, politically exposed persons (PEPs), and adverse media forms part of our customer due diligence procedures and ongoing monitoring.

5.  Politically Exposed Persons (PEPs)

We assess whether a client or beneficial owner is a politically exposed person (PEP), or a family member or close associate of a PEP.

Where a PEP relationship is identified:

  • Enhanced due diligence measures are applied

  • Senior management approval is obtained before establishing or continuing the relationship

  • The source of funds and, where appropriate, source of wealth are assessed

  • Enhanced ongoing monitoring is performed

6.  Sanctions and Screening

We conduct sanctions, politically exposed persons, and adverse media screening on clients and, where applicable, beneficial owners.

Screening is performed at onboarding and on an ongoing basis using third-party data providers, including ComplyAdvantage.

This includes continuous monitoring for changes in sanctions status, PEP classification, and relevant adverse media.

All alerts are reviewed, documented and, where appropriate, escalated in accordance with our internal procedures.

7.  Suspicious Activity Reporting

All employees are required to report any suspicion of money laundering or terrorist financing internally without delay.

Where appropriate, we will file a report with the Cellule de Renseignement Financier (CRF) in accordance with Luxembourg law.

8.  Record Keeping

We retain records relating to:

  • Client identification

  • Transactions

  • Due diligence

For a minimum of five (5) years, in accordance with applicable legal and regulatory requirements.

9.  AML Governance

We have appointed a designated person responsible for the implementation and oversight of our anti-money laundering procedures.

This includes responsibility for:

  • Maintaining AML policies and procedures

  • Monitoring compliance

  • Reviewing and escalating matters where appropriate

  • Acting as the primary point of contact for regulatory authorities

10.  Training

We ensure that all relevant personnel:

  • Receive regular AML training

  • Understand their obligations

  • Are able to identify and report suspicious activity

11.  Data Protection

Personal data collected for AML purposes is processed in accordance with applicable data protection laws, including the GDPR.

12.  Review

This policy is reviewed periodically and updated as required to reflect legal, regulatory, and operational changes.

Previous AML Policy