Compliance Policy (KYC/AML)

As a financial intermediary, we are subject to due diligence obligations towards our clients. This procedure, known as "Know Your Customer" (KYC), requires us to verify the identity of our clients and the origin of funds before any transaction.

1. Client Identification (KYC)

For each financing file, we strictly require:

• Valid official identity document (ID Card, Passport).
• Proof of address dated less than 3 months.
• For companies: Certificate of Incorporation (or equivalent) dated less than 3 months and up-to-date Articles of Association.
• Identification of Ultimate Beneficial Owners (UBO) holding more than 25% of the capital.

2. Source of Wealth

We must understand the economic consistency of the transaction. We may ask you for:

• Recent bank statements.
• Audited financial statements.
• Proof of income (salaries, dividends, real estate sale...).
• An explanation of the intended use of the borrowed funds.

3. Transaction Monitoring (AML)

We analyze financial flows to detect any anomalies:

• Amounts inconsistent with the client's profile.
• Complex transactions with no apparent economic justification.
• Transactions involving high-risk countries (FATF/EU list).

4. Suspicious Activity Reporting

In accordance with the law, STPI Finance reserves the right to refuse any business relationship if client identification is impossible or doubtful. In the event of proven suspicion of money laundering, a report will be made to the competent Financial Intelligence Unit (NCA in the UK or local equivalent).

5. International Sanctions

We do not process any transactions with persons or entities appearing on international sanctions lists (UN, EU, OFAC/USA, HMT/UK).