Anti-Money Laundering, Countering the Financing of Terrorism & Sanctions Policy
Jurisdiction: Republic of Seychelles
| Company Name | NexGen Tech Incorporated |
|---|---|
| Registration Number | 227642 |
| Registered Address | Seat at House of Francis, Room 303, Ile Du Port, Mahe, Seychelles |
| Regulatory Framework Baseline | Anti-Money Laundering and Countering the Financing of Terrorism Act, 2020 (as amended up to 2025/2026) |
Primary Identification: To verify individual identities, applicants must upload an unaltered, valid, high-resolution scan of their government-issued International Passport or National Identity Card. All fields must be readable and in Latin/English alphabet characters.
Biometric Liveness Verification: Applicants must provide a clear photographic image or live biometric video capture of themselves holding their primary identification document. The document text and the user's face must be simultaneously visible and readable. If technical interface or camera errors occur during standard web form submission, applicants are permitted to securely transmit this imagery via email.
Data Quality Standards: Submissions that display poor resolution, blurriness, or obfuscated data fields will be rejected, resulting in an 'Incomplete KYC Profile' status until remediation.
Prohibited Documents: Standard Motor Vehicle Driving Licenses are explicitly disallowed as a valid standalone document for verifying identity.
Legal entities pose a structurally higher risk due to multi-layered operational transparency constraints. NexGen Tech Incorporated mandates the comprehensive collection and verification of foundational corporate documents prior to account activation or fund execution.
Seychelles-Domiciled Legal Entities:
Foreign (Non-Seychelles) Domiciled Legal Entities:
Mandatory Control Investigation: In full alignment with Seychelles Beneficial Ownership Regulations, NexGen Tech Incorporated conducts rigorous tracing to reveal the individual natural persons holding ultimate controlling interest or ownership in any legal entity client. Control thresholds isolate individuals exercising control through ownership percentage, vote orchestration, or senior executive management roles. No corporate relationship will be finalized or permitted to process fund transactions until every underlying UBO has been fully identified and verified.
NexGen Tech Incorporated applies a strict automated country risk metric synchronized dynamically with the Financial Action Task Force (FATF) Plenary updates up to June 2026.
Protocol (Risk Score 12): Systems will automatically refuse registration requests or transactions stemming from these jurisdictions. Immediate files are passed to the MLRO/Compliance Officer to log a Suspicious Activity Report (SAR).
Active Country Registry (June 2026): Iran, Democratic People’s Republic of Korea (DPRK), and Myanmar.
Protocol (Risk Score 6): Applications originating from these jurisdictions will not have their registrations automatically rejected, but will initially fall under the Medium Risk category and have a baseline score of 6 applied on the risk scale, requiring mandatory Enhanced Due Diligence (EDD) and manual approval.
Active Country Registry (June 2026): Angola, Bolivia, Bosnia and Herzegovina, Bulgaria, Cameroon, Côte d'Ivoire, Democratic Republic of the Congo, Haiti, Iraq, Kenya, Kuwait, Lao PDR, Lebanon, Monaco, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, British Virgin Islands (BVI), and Yemen. (Note: Following the June 2026 FATF Plenary, Algeria and Namibia have been officially removed from the monitored list and are no longer subject to baseline score-6 constraints).
The company maintains automated web-based screening integrations alongside manual search tools via established databases (e.g., WorldCompliance) to run full-scope name matching at onboarding and on an ongoing daily batch routine.
During onboarding, metrics regarding Net Worth, Gross Annual Income, and Expected Investment sizes are captured. The compliance matrix evaluates variations via automated calculations:
If Planned Investment > Gross Annual Income:
- If Net Worth > Planned Investment: Apply a minor risk modifier of +4.
- If Net Worth <= Planned Investment: Apply an elevated risk modifier of +7.
If Planned Investment <= Gross Annual Income: Apply a risk modifier of 0.
Exclusion of Anonymity & Threshold Rules: To mitigate the systemic anonymity and cross-border segmentation risks inherent to virtual asset environments, transactions involving unidentifiable users or mixing platforms are strictly blocked. Virtual currency transactions exceeding 15,000 EUR (or equivalent) require documented confirmation of the sender's wallet address history, transaction provenance, and balances.
The operational environment manages account behavior based on three distinct risk tiers derived from the final calculated risk scores:
| Client Risk Tier | Total Risk Score | Auto-Processing Limits | Declaration of Source of Funds (DSF) | Required Update Frequency |
|---|---|---|---|---|
| Low Risk | 0 to 4 | Transactions < 50,000 SCR | Discretionary / Triggered if > 50,000 SCR | At least once every 4 Years |
| Medium Risk | 5 to 8 | Transactions < 50,000 SCR | Discretionary / Triggered if > 50,000 SCR | At least once every 3 Years |
| High Risk | 9 to 12 | 0% (100% Manual Review) | Mandatory for any transaction > 50,000 SCR | At least once every 1 Year (Annually) |
Remediation for Failed Validation: If a requested Declaration of Source of Funds (DSF) is missing, rejected, or cannot be traced to a verified bank account under the name of a registered client, the fund transfer will be reversed, and a formal SAR will be drafted by the Compliance Officer.
Reporting Obligation: When compliance operations identify a definitive high-risk event, clear criminal activity, or a confirmed sanctions hit, information must be transmitted to the Seychelles Financial Intelligence Unit (FIU) within two business days.
Legal Prohibition: Pursuant to Section 50 of the AML/CFT Act 2020, NexGen Tech Incorporated, its corporate officers, and its operational staff are legally prohibited from disclosing to a client, UBO, or associated third party that an investigation is active, or that an STR/SAR has been transmitted to the FIU. Any breach of this confidentiality provision will result in severe internal disciplinary action and immediate referral to local law enforcement authorities.
Retention & Accessibility: All foundational identity documentation, wallet addresses, transaction files, internal review logs, and cross-checking reports will be archived securely within encrypted corporate servers for a minimum period of 7 years following the official termination of the client relationship. Data access parameters guarantee that records can be compiled and made accessible to the Seychelles FIU within two business days of a formal production request.