1. Purpose
Helvetica Credit Investment AG is committed to preventing its platform from being used for money laundering, terrorist financing, sanctions evasion or any other financial crime. This policy summarises the framework we apply in accordance with the Swiss Anti Money Laundering Act, the Anti Money Laundering Ordinance, the guidance of the Swiss Financial Market Supervisory Authority and the recommendations of the Financial Action Task Force. It is binding on all employees, officers and service providers acting on our behalf.
2. Governance
Our Chief Compliance Officer is responsible for the design and operation of the anti money laundering programme, for reporting to the board of directors and for liaison with the Money Laundering Reporting Office Switzerland. Compliance staff are independent of client facing and investment functions. All employees receive training on onboarding and at least annually thereafter.
3. Client identification
We identify every client before accepting deposits above the basic threshold and before processing withdrawals above the basic daily limit. Natural persons must provide a valid government issued identity document, a selfie holding the document, and a proof of residential address issued within the last three months. Legal entities must provide constitutional documents, a current register extract, identification of directors and beneficial owners holding twenty five percent or more, and evidence of the authority of the person acting on their behalf. Verification is tiered. Tier one requires a verified email address. Tier two requires identity document and selfie. Tier three additionally requires proof of address and, where applicable, source of funds evidence. Limits attached to each tier are displayed in the client portal.
4. Beneficial ownership
We establish the identity of the beneficial owner of every account. Accounts may not be operated on behalf of undisclosed third parties. Clients must confirm that they act for their own account or disclose the beneficial owner by written declaration.
5. Politically exposed persons and sanctions screening
We screen clients and beneficial owners against sanctions lists maintained by the Swiss State Secretariat for Economic Affairs, the United Nations, the European Union and the Office of Foreign Assets Control, and against lists of politically exposed persons. Business relationships with politically exposed persons require senior management approval and are subject to enhanced ongoing monitoring. We do not accept clients who are subject to sanctions or who are resident in jurisdictions identified as high risk by the Financial Action Task Force.
6. Source of funds and source of wealth
For deposits exceeding the enhanced due diligence threshold, for clients classified as higher risk, and whenever a transaction appears inconsistent with a client profile, we request evidence of the origin of funds such as bank statements, payslips, sale agreements or tax returns. Where source of funds cannot be satisfactorily established, deposits are returned to the originating account and the relationship may be terminated.
7. Ongoing monitoring
Transactions are monitored continuously using automated rules that flag unusual size, frequency, structuring patterns, rapid movement of funds without an investment purpose, and inconsistency with the client profile. Flagged activity is reviewed by compliance staff. We may delay transactions, request information or restrict an account while a review is in progress. Client information is refreshed periodically, at least every three years for standard risk clients and annually for higher risk clients.
8. Record keeping
Identification documents, transaction records and the results of monitoring and investigations are retained for ten years after the end of the business relationship or the completion of the transaction, whichever is later. Identity documents are stored encrypted outside the public web root and access is restricted to authorised compliance staff. Access is logged in an immutable audit trail.
9. Reporting
Where we have reasonable grounds to suspect that assets are connected to a criminal offence, originate from a crime, or are subject to the power of disposal of a criminal or terrorist organisation, we file a report with the Money Laundering Reporting Office Switzerland and comply with any resulting instructions. Swiss law prohibits us from informing the client that a report has been made.
10. Client obligations
Clients must provide accurate information, respond to compliance requests promptly, deposit only from accounts in their own name, withdraw only to accounts or addresses they control, and inform us of any material change in their circumstances. Failure to cooperate may result in restriction or closure of the account.
11. Review
This policy is reviewed at least annually by the Chief Compliance Officer and approved by the board of directors. The current version is always published on this page.
Helvetica Credit Investment AG, Bahnhofstrasse 64, 8001 Zürich, Switzerland. Registered in the Commercial Register of the Canton of Zurich. VAT CHE-383.300.010 MWST.