1. Our approach
3-102-968550 Sociedad de Responsabilidad Limitada treats financial crime prevention as an operating requirement rather than a formality. Screening, due diligence and monitoring sit on the transaction path itself, so the record they produce is a by-product of normal operation.
This policy describes our internal practice. It is not legal advice and does not relieve any client of its own obligations.
2. Risk-based framework
We assess risk before onboarding and reassess it periodically. The factors we weigh include the client's jurisdiction and that of its customers, its ownership and control structure, the nature of its business, the payment model, expected volumes, and the assets and networks involved.
The depth of due diligence and the intensity of monitoring are set by that assessment. A higher-risk relationship attracts more evidence, tighter thresholds and more frequent review.
3. Customer due diligence and know your customer (KYC)
Before providing services we identify and verify the client, its beneficial owners and the people authorised to act for it, the standard Know Your Customer (KYC) check behind every onboarding. We establish the nature and purpose of the relationship, the source of funds where relevant, and the business model behind the expected payment volume.
Enhanced due diligence applies where risk is elevated, including where a politically exposed person is involved, where ownership is opaque, or where a jurisdiction carries heightened risk.
Records are kept current. A material change in ownership, jurisdiction or activity triggers a review rather than waiting for the next scheduled cycle.
4. Transaction monitoring
Incoming payments are screened on arrival and outgoing payouts before release. Every address in the flow is scored on the exposure behind it: what it has interacted with, how funds reached it, and its distance from known high-risk sources.
Activity is also compared against the profile agreed at onboarding. Volume that jumps without explanation, counterparties that appear from nowhere, structuring patterns, and flows through mixing services all raise alerts.
Alerts are worked by people, not closed by a script. Each one is investigated, resolved and recorded with the reasoning attached.
5. Sanctions and screening
Clients, beneficial owners and counterparties are screened against applicable sanctions lists at onboarding and rescreened as those lists change. Screening also covers politically exposed persons and adverse media.
A confirmed match stops the transaction and follows the escalation procedure agreed in advance. We do not process transactions where doing so would breach applicable sanctions.
6. Prohibited activity
We do not knowingly provide services in connection with: money laundering or terrorist financing; sanctions evasion; darknet marketplaces; ransomware or extortion proceeds; fraud or phishing schemes; unlicensed gambling where a licence is required; the sale of illegal goods or services; child sexual abuse material; or any activity prohibited by applicable law.
We also decline relationships where the source of funds cannot be established to our satisfaction.
7. Reporting and cooperation
Where a suspicion arises that cannot be resolved, we report it to the competent authority in accordance with applicable law. We cooperate with lawful requests from authorities. Where the law prohibits disclosure of a report to the client, we do not disclose it.
8. Record keeping
Due diligence records, transaction data, screening results and case histories are retained for the period applicable law requires, which is typically several years after the relationship ends, and are available to authorities on a lawful request.
9. Internal controls
Responsibilities are assigned and documented. Risk appetite, thresholds and escalation levels are set in writing before a relationship goes live, and the same rule produces the same outcome regardless of who is on shift. Anything outside the rules reaches an accountable person rather than a queue.
Staff involved in onboarding and monitoring receive training appropriate to their role, and our procedures are reviewed periodically.
10. Updates
This policy is reviewed as our practice and the applicable rules develop. The version published on this page is the current one.
Questions: compliance@solvexadigital.com.