This document forms part of the agreement between you and Entity Makers. If any term is unclear, contact us at info@entitymakers.com.
1. Purpose & Scope
Entity Makers is committed to preventing money laundering, terrorist financing, and other financial crime. This Anti-Money Laundering (AML) Policy sets out the standards applied across every service line — USA LLC and UK LTD formation, banking and Stripe introductions, e-commerce onboarding and website development — and reflects our obligations under the UK Money Laundering Regulations 2017, the US Bank Secrecy Act, and FinCEN's Corporate Transparency Act.
2. Customer Due Diligence (CDD)
Before starting work we identify and verify every customer, including:
- Legal name, date of birth and nationality of the individual placing the order.
- Directors, shareholders, and beneficial owners holding 25% or more.
- Business activity, source of funds, and expected transaction volume.
- Country of residence and residential address.
3. Risk Assessment
Each engagement is scored against a risk matrix that considers geography (high-risk and sanctioned jurisdictions), industry (adult, gambling, crypto, precious metals), politically exposed persons (PEP) exposure, ownership complexity and payment method. Higher-risk engagements trigger Enhanced Due Diligence (EDD).
4. Identity Verification
We verify identity using government-issued photo ID (passport, national ID, driving licence), a liveness selfie, and address confirmation (recent utility bill or bank statement). Verification is carried out via industry-standard providers with biometric matching and document authenticity checks.
5. Suspicious Activity
Staff are trained to spot red flags including inconsistent documentation, unusual payment routing, reluctance to provide beneficial owner information, and requests for unnecessary anonymity. Any suspicion is escalated to our Compliance Officer, who is empowered to pause work and, where required by law, file a Suspicious Activity Report (SAR) with the relevant authority.
6. Record Keeping
All KYC documents and transaction records are retained securely for a minimum of 5 years after the end of the business relationship, as required by UK MLR 2017 and equivalent US regulations.
7. Compliance Programme
Our AML programme includes:
- A designated Compliance Officer accountable to senior management.
- Annual AML training for every client-facing team member.
- Regular sanctions and PEP screening against OFAC, UN, EU and UK lists.
- Independent review of policies and procedures at least annually.
8. Reporting & Cooperation
We cooperate fully with law enforcement and regulatory requests made under lawful authority. For AML enquiries, contact our Compliance Officer at info@entitymakers.com.
