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AML Policy

Last updated: 2025.

1. Purpose and Legal Basis

RackRent Systems LTD ("Company") operates in compliance with the EU Anti-Money Laundering Directive (6AMLD) and related national legislation. This Policy describes our approach to the prevention of money laundering (AML), terrorist financing (CTF), and sanctions evasion.

2. KYC Procedure (Know Your Customer)

Before providing certain services, the Company may be required to verify the client's identity. The KYC procedure includes:

  • For individuals: passport or national identity document + selfie with document
  • For legal entities: authorised person's document (passport + selfie) + company incorporation documents (certificate of registration or equivalent)

The Company reserves the right to refuse or discontinue services if KYC is not completed or if submitted documents raise reasonable concerns.

3. Risk Assessment

We conduct a risk-based assessment of each client, taking into account:

  • Client jurisdiction and country of business registration
  • Type of services requested and transaction volume
  • Consistency of client profile and declared business activities
  • Presence on sanctions lists (OFAC, EU)
  • PEP (Politically Exposed Person) status

Clients with an elevated risk profile may be subject to Enhanced Due Diligence.

4. Sanctions Screening

Before establishing a business relationship and on an ongoing basis, the Company screens clients and beneficial owners against OFAC (US), EU Council, and other applicable sanctions lists. Services are refused to sanctioned individuals and entities.

5. Transaction Monitoring

The Company conducts ongoing monitoring of client business relationships and transactions. Indicators of suspicious activity include:

  • Unusually large or atypical transactions
  • Payments to/from high-risk jurisdictions
  • Use of services in ways inconsistent with the stated business
  • Attempts to anonymise transactions or evade verification

6. Reporting Obligations

Upon identifying signs of money laundering or terrorist financing, the Company is obligated to file a Suspicious Activity Report (SAR) with the competent financial intelligence authority. The client is not notified of this ("tipping off" is prohibited by law).

7. Record Keeping

KYC documents and transaction records are retained for a minimum of 5 years from the end of the business relationship, in accordance with 6AMLD and GDPR requirements.

8. Zero Tolerance

The Company maintains a zero-tolerance policy towards all forms of money laundering, terrorist financing, and sanctions evasion. Detection of such activity results in immediate termination of the agreement and referral to law enforcement authorities.

9. Contact

For questions related to this policy, please contact us via the contact form.