Legal Documents
[I] Prohibitions
Bilderlings has no appetite for customers or contractors, who engage in any of the following:
- Intentional or willfully negligent breaches of law, regulation or policy concerning Financial Crime and/or fraud and/or Sanction’s violation;
- Repeated unintentional or repeated accidental breaches of law, regulation or policy concerning Financial Crime and/or fraud and/or Sanction’s violation;
- Misusing Bilderlings products and services for the purpose of money laundering, terrorism financing, proliferation, Sanction violation or fraud;
- Facilitating business activities, which could be interpreted as a tax offence; and
- Refusing to provide sufficient information or documentation to demonstrate compliance.
Bilderlings is aiming to conduct business only with reputable customers or contractors and whose identities can be reliably determined and verified.
Bilderlings reserves the right to terminate relationships with any customer or contractor, refuse payment, or business that is not compliant with Bilderlings’ risk appetite.
Bilderlings will not knowingly enter into a business relationship with customers that seek to process payments involving:
- Illegal Gambling entities;
- Weapon dealers/intermediaries/purchasers;
- Illegal drugs;
- Anonymous accounts or customers seeking to maintain an account in an obviously fictitious name;
- Human Trafficking or Modern Slavery;
- Shell Banks, i.e. banks with no physical presence or staff, or financial institutions which cooperates with shell banks;
- Adult-online live content, webcam, online streaming content and acts of offensive adult content, Adult advertising, Child Pornography, Bestiality;
- Rape/Hate/Violence;
- Replica/Copyright infringement;
- Companies which issue bearer shares;
- Unlicensed financial institutions;
- Privacy coins e.g. Monero, Zcash and Dash;
- Ponzi / pyramid schemes; and
- Binary options
Bilderlings Risk Appetite with respect to higher risk customers focuses on the establishment of ongoing processes of developing, updating and implementing internal controls, in order to detect, prevent and minimise the risk of Bilderlings being used for ML/TF, proliferation or Sanction violations.
Bilderlings uses appropriate measures and controls to mitigate the potential ML/TF, proliferation or Sanction violation risk of those customers/transactions that are determined as high risk. These measures include:
- Increased awareness of higher risk situations within business lines through enhanced and specialised training;
- Increased levels of know your customer (“KYC”) and know your customer’s business (“KYCB”) and enhanced due diligence for high risk customers, including PEPs;
- Escalation for approval of the establishment of a new, or the maintenance of an existing, business relationship;
- QA of customer’s onboarding by both the AML and Compliance teams;
- Periodic KYC reviews for all customers, which includes a review of all kyc documents obtained during onboarding to ensure they remain up to date as well as ongoing scrutiny of the customer’s transactions;
- Customer and Payment screening for sanctions purposes; and
- Automated transaction monitoring of all transactions post event.
* weapons of war, automatic weapons, ammunition or defence equipment, chemical weapons, cluster bombs, ammunitions, or other defence equipment or similar
Approved on 31/01/2024 Board meeting (AML-STA-001)
[II] Banned CountriesNb
Bilderlings has no appetite for customers or contractors who are registered, or are citizens or residents, of the following countries R . Further we should not accept payments from these countries either from the customer directly or via the customer’s business partners:
- Afghanistan;
- American Samoa c ;
- Barbados c ;
- Botswana c ;
- Burundi c ;
- Cambodia c ;
- Cameroon c ;
- Central African Republic;
- Chad c Cuba;
- Eritrea c
- Ethiopia,
- North Korea (DPRK);
- Democratic Republic of the Congo c ;
- Fiji c ;
- Gabon c
- Guam c ;
- Iran;
- Iraq;
- Lebanon;
- Libya;
- Mali c ;
- Mozambique c ;
- Myanmar (Burma) c ;
- Nicaragua c ;
- Nigeria c ;,
- Pakistan c ;
- Palau c ;
- Palestine;
- Samoa c ;
- Senegal c ;
- Somalia;
- South Sudan;
- Sudan; Syria;
- Trinidad and Tobago c ;
- Uganda c ;
- Venezuela;
- Yemen;
- Zimbabwe; g
- overnment and non-government controlled Ukrainian territory***
Contested territories that are not internationally recognized:
- Transdniestria,
- The Crimea Region (Ukraine),
- Abkhazia,
- South Ossetia etc.**
Nb If the If a new country is added to the Banned Country list, Bilderlings may continue business relations with a client who is a resident or citizen of that country, subject to the relevant decision of the FCC.
** Contested territories that are not internationally recognized refer to regions that have declared independence or autonomy from a recognized state, but their sovereignty is not recognized by the international community.
*** means areas of the Donetsk, Kherson Luhansk and Zaporizhzhia oblasts; We do not open accounts for clients from these territories; However, the payments from/to Ukrainian governmentally controlled territories of Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts could be made, if it does not breach the sanctions and relevant UK law (manually evaluate sanction risk case by case. For the purpose of mentioned above: non-government controlled areas of the Donetsk, Kherson Luhansk and Zaporizhzhia oblasts means the parts of the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts which are for the time being controlled by an authority other than the Government of Ukraine .
R ban on account opening does not apply on citizens of the countries with residence permit in UK, EEA and Switzerland, with proven residence address in the country of residence permit.
Cards services related limitations
Bilderlings Cards are not operating in Ethiopia, Russia and Banned Countries (except for those Banned Countries marked as “c” ).