Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policies and Principles


Money laundering and terrorist financing have been identified as major threats to the international financial services community.

The European Union and its member states, in common with many other countries, has passed legislation designed to prevent money laundering and to combat terrorism.

This legislation, together with regulations, rules and industry guidance, forms the cornerstone of AML/CTF obligations for EU firms and outline the offences and penalties for failing to comply.

Investinero Ltd is not authorised or regulated by the EU regulators and at present does not fall under regulated category. Nevertheless, taking into account changing rules, country and international legislation and the fast development of the fintech and auxiliary services, such as crowdsourcing and alternative payment systems, the management of the company has identified the need to implement the necessary systems and controls within the company equal to best practices of regulated financial institutions.

Being compliant and utilising risk-based approach to evaluation of the business practices shall help the company be positively placed ahead of the imminent future tightening and regulating of the market, as well as making its business safer.

Investinero Limited takes into consideration various international legal frameworks when planning its operations.  Sources include but are not limited to Estonian Financial Supervision Authority, UK Financial Conduct Authority (FCA), Wolfsberg Group, UK Proceeds of Crime Act (Amendment) Regulations 2007;  UK Terrorism Act 2006; UK Bribery Act 2010; UK Money Laundering Regulations 2007, EU’s Third and Fourth Money Laundering Directive; The Joint Money Laundering Steering Group (JMLSG) Guidance, US Patriot Act and guidance by US OFAC.

Investinero Ltd Policies & Principles: Organisation’s Team owns and is responsible for the following Policies covering:

  1. Anti-Money Laundering/Counter-Terrorist Financing (AML/CTF);
  2. Sanctions;
  3. Anti-Bribery & Anti-Corruption;

These policies and principles are designed to ensure that the company complies with the legal and regulatory requirements applicable in the EU as well as with their local obligations in member states.


  1. Anti-Money Laundering (AML) Policy:

Policy is designed to ensure that all Group Companies comply with the requirements and obligations set out in EU legislation, regulations, rules and Industry Guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime.

The AML Policy sets out the minimum standards which must be complied with by all departments:

  • The appointment of a Group Money Laundering Reporting Officer (GMLRO) and Business Unit Money Laundering Reporting Officers (MLROs) of sufficient experience, who have responsibility for oversight of Business Unit compliance with relevant legislation, regulations, rules and industry guidance;
  • Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;
  • Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs) and relationships with providers of financial services;
  • Establishing and maintaining risk based systems and procedures to monitor ongoing customer activity;
  • Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
  • The maintenance of appropriate records for the minimum prescribed periods;
  • Training and awareness for all relevant employees; and
  • The provision of appropriate management information and reporting.


  1. Sanctions Policy:

Investinero Limited Sanctions Policy is designed to ensure that the company complies with applicable sanctions laws in every jurisdiction in which it operates. All clients and vendors are screened against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists at a minimum in all jurisdictions in which our clients may operate, unless to do so would conflict with local legislation.

All employees receive training on the Sanctions Policy at least once a year, with more detailed and advanced training for those whose roles involve heightened sanctions risks. Failure to comply with the policy may give rise to disciplinary action, up to and including dismissal.


  1. Anti-Bribery & Anti-Corruption Policy:

Investinero Limited has a zero tolerance policy towards bribery and corruption and recognises that bribery and corruption have an adverse effect on communities wherever they occur. They can threaten laws, democratic processes and basic human freedoms, impoverishing states and distorting free trade and competition. Corruption is often associated with organised crime, money laundering and on occasions the financing of terrorism. In addition, the level and efficacy of investment and financing can be reduced, particularly within economically disadvantaged societies.

Company is committed to applying high standards of honesty and integrity consistently and in all our business dealings.

Reference:  Wolfsberg_Questionnaire