Anti-Money Laundering Policy of Capitalista

Commitment Statement

Capitalista is dedicated to preventing money laundering, terrorism financing, and the circumvention of sanctions. We prioritize compliance with applicable laws and regulations to protect our reputation and maintain public trust in our services.

To ensure effective implementation of our policies, Capitalista has established an Anti-Money Laundering (AML) policy that outlines the required measures for compliance with the Swiss regulatory framework. This policy applies to all businesses associated with Capitalista.

Political Objectives

  1. Establish clear policies regarding money laundering, terrorism financing, and the avoidance of sanctions.
  2. Clearly define compliance responsibilities that all employees are obligated to follow.
  3. Provide guidance to employees on their daily business activities in line with legal requirements.
  4. Foster a work environment that promotes a culture of regulatory compliance.

Definition of Money Laundering

In accordance with Swiss law, money laundering is defined as the act of engaging in activities that involve the transfer or management of funds known to be derived from criminal activity, with the intent to conceal the origin of those funds. This includes:

  • Concealing the true nature, source, or location of the proceeds.
  • Acquiring, possessing, or using the proceeds after their receipt.
  • Assisting the individual who committed the crime to evade prosecution.

It is crucial to note that money laundering is a deliberate act and cannot occur through mere negligence. However, Capitalista acknowledges that gross negligence, particularly the failure to report suspicious activities to the authorities, may have legal consequences.

Laws and Regulations

Capitalista adheres to the following Swiss laws and regulations:

  • Swiss Federal Act on Combating Money Laundering and Terrorist Financing (AMLA)
  • Ordinance on Combating Money Laundering and Terrorist Financing
  • Relevant United Nations sanctions applicable in Switzerland

Swiss financial institutions are required to follow a risk-based approach to meet their legal obligations. Capitalista is committed to implementing a robust compliance program that aligns with legal requirements and industry best practices.

Reporting and Investigation

The Swiss Financial Market Supervisory Authority (FINMA) oversees the reporting and investigation of suspected illegal financial activities. In cases of suspected money laundering, Capitalista will promptly report these instances to the relevant authorities.

Transaction Monitoring System

Capitalista has implemented a transaction monitoring system to identify any transactions that appear unusual or suspicious. All transactions undergo manual review, and we are in the process of implementing an automated system to enhance efficiency and effectiveness.

Identification of Suspicious Transactions

Given our business model, Capitalista conducts thorough due diligence for each transaction. This rigorous process is designed to identify transactions with unusual or irregular characteristics that may indicate potential suspicious activities.

Reporting Suspicious Transactions

Capitalista fulfills its obligation to report any transactions deemed suspicious through established channels. Such transactions are reported promptly to the Swiss Financial Intelligence Unit (FIU).

Document Retention

Capitalista maintains a diligent approach to document retention, ensuring that all relevant records are securely kept for a minimum of ten years, in compliance with legal and regulatory requirements.

Risk Assessment

A dedicated risk management unit at Capitalista conducts comprehensive risk assessments of customer profiles, ensuring that potential risks are effectively identified and mitigated in accordance with legal and regulatory frameworks.

Compliance Team

Capitalista has appointed a compliance officer responsible for overseeing the AML program and ensuring adherence to legal obligations. The compliance team regularly conducts audits and training to ensure that all employees are aware of their responsibilities regarding AML practices.

Training and Awareness

All employees at Capitalista receive annual training on AML and counter-terrorism financing (CFT). Training topics include identifying and reporting suspicious transactions, understanding the forms of money laundering, and internal procedures for preventing money laundering.

Capitalista is committed to maintaining the highest standards of compliance and ethics in all business operations. By fostering a culture of awareness and responsibility, we aim to contribute to the integrity of the financial system in Switzerland.