Legal
Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy
1. Purpose and Scope
This policy is designed to:
- Prevent the Company from being used to facilitate money laundering or terrorist financing.
- Ensure that we meet our legal and regulatory obligations under applicable AML laws in the jurisdictions we operate (e.g., Nigeria, UAE, UK, US).
- Promote transparency and integrity in all business relationships.
It applies to:
- All employees, consultants, partners, and agents of Leyton Energie Trading LLC;
- All customers, clients, and counterparties engaging with the Company.
2. Definition of Money Laundering
Money laundering refers to any act designed to conceal or disguise the origins of illegally obtained money to make it appear to be from legitimate sources. It generally includes three stages:
- Placement – introducing illicit funds into the financial system.
- Layering – moving funds through multiple transactions to obscure their source.
- Integration – using the funds for legitimate investments or purchases.
3. Customer Due Diligence (CDD)
Before entering into any business relationship, the Company will perform the following CDD measures:
a. Individual Clients
- Full legal name
- Government-issued identification (e.g., International Passport, National ID, Driver’s License)
- Proof of residential address
- Source of funds and wealth
- Politically Exposed Person (PEP) screening
- Biometric or digital verification (where applicable)
b. Corporate Clients
- Certificate of incorporation
- Company bylaws or constitution
- Proof of registered office address
- Identification documents for directors and ultimate beneficial owners (UBOs)
- Tax Identification Number (TIN)
- Audited financial statements or banking references
4. Enhanced Due Diligence (EDD)
Enhanced measures will be applied where:
- The client is a Politically Exposed Person (PEP);
- The transaction involves high-risk countries or sectors;
- There are doubts about the veracity of client-provided documents;
- The transaction is unusually complex or lacks an apparent lawful purpose.
5. Ongoing Monitoring
We shall continuously monitor business relationships to:
- Identify suspicious patterns or activities;
- Ensure consistency between the client’s activity and profile;
- Update KYC documentation regularly;
- Reassess client risk profiles as necessary.
6. Record-Keeping
Leyton Energie Trading LLC will maintain detailed records of:
- All CDD and EDD documents;
- Transaction histories;
- Internal reports and investigations;
- Communications relating to client relationships.
Records will be kept for a minimum of 5 years from the end of the business relationship or date of transaction, whichever is later.
7. Suspicious Activity Reporting
All employees must report any suspicions of money laundering or unusual activity to the designated AML Compliance Officer. The Company shall file Suspicious Activity Reports (SARs) with the appropriate financial intelligence unit (FIU) or regulatory authority when required by law.
8. Training and Awareness
All relevant staff shall undergo periodic AML/KYC training to ensure:
- Familiarity with red flags and high-risk transactions;
- Awareness of their obligations under this policy and relevant laws;
- Effective escalation of suspicious matters to the Compliance Officer.
9. Sanctions and Prohibited Parties
Leyton Energie Trading LLC strictly prohibits doing business with:
- Entities or individuals listed on international sanctions lists (e.g., OFAC, EU, UN);
- Shell banks or anonymous accounts;
- Persons or entities involved in criminal or terrorist activities.
All prospective partners are screened against global sanctions databases and watchlists.
10. Review and Updates
This AML/KYC Policy is reviewed annually or more frequently if necessary to reflect:
- Regulatory changes;
- Industry best practices;
- Operational risks or structural adjustments.
11. Contact Information
For questions or reports relating to this AML/KYC Policy, please contact:
Compliance Officer
Leyton Energie Trading LLC
46 Prince Street, Suite 306
New Haven, CT 06519
📧 Email: compliance@leytonenergie.com