Our commitment
Sepa Mint does not accept business that it believes is connected to money laundering, terrorist financing, fraud, sanctions evasion or other financial crime. We apply a risk-based approach across onboarding and the life of every client relationship, and we work alongside our banking and payment partners, whose own controls also apply.
Client due diligence
Every client is verified before the service goes live. What we ask for depends on the client type, the transaction type and the expected value and volume.
- Businesses (KYB): certificate of incorporation, share register, ultimate beneficial owner (UBO) details.
- Individuals (KYC): UBO government-issued photo ID and proof of address.
- Enhanced due diligence for higher-risk clients, including source of funds and source of wealth checks where needed.
Verification requirements can change during the relationship, and we may ask for more information at any time.
Sanctions and screening
Clients, their owners and directors are screened against applicable sanctions lists, politically exposed person (PEP) lists and adverse media before onboarding and on an ongoing basis. Settlement wallets are screened using blockchain analytics. We do not provide services to sanctioned persons or to restricted jurisdictions.
Ongoing monitoring
We monitor account activity for transactions that are unusual for the client's profile, including unexpected volumes, ticket sizes, counterparties or jurisdictions. Payments that raise concerns may be held while we review them.
Prohibited activity
We do not onboard, or we exit, clients involved in:
- unlicensed activity in any jurisdiction where a licence is required;
- shell banks or businesses with ownership we cannot verify;
- fraud, scams, illegal goods or services, or the proceeds of crime;
- attempts to evade sanctions, reporting obligations or our controls.
The full list of restricted business types and jurisdictions is shared during onboarding. [Attach or link the restricted list]
Reporting and record keeping
Where we or our partners suspect money laundering or terrorist financing, we report it to the relevant authorities as the law requires. We will not tell a client that a report has been made where doing so is prohibited.
Verification and transaction records are kept for at least [5] years after the relationship ends, or longer where the law requires.
Our right to refuse or close accounts
We may decline an application, hold or return funds, or suspend or close an account where we cannot complete our checks, where information provided is false or incomplete, or where we believe the activity breaches this policy or the law.
Governance and training
A designated compliance officer oversees this policy, which is reviewed at least once a year. Staff involved in onboarding and operations receive regular financial crime training. [Name or title of compliance officer]
Contact
Questions about this policy can be sent to [compliance@sepamint.com].