Anti-Money Laundering and Anti-Financial Crime Policy


Given the nature of Terrapinn’s business, the Board believes the risk of the business being used by third parties for the money laundering purposes and related to be low.

Nonetheless, Terrapinn is committed to the highest standards of Anti-Money Laundering (AML) and Anti-Financial Crime (AFC) including Anti-Bribery and Corruption (ABC), Counter Terrorism Financing (CTF), Anti-Fraud and other punishable criminal acts. All employees are required to adhere to these standards to protect Terrapinn and its reputation from being misused for money laundering and/or terrorist financing or other illegal purposes.

Terrapinn will adhere to all applicable laws and regulations in all countries where it conducts business, or has business relationships with.

Terrapinn will examine its AML and AFC strategies, goals and objectives on an ongoing basis and maintain an effective program for the business.

The program is formulated and directed by the Board and addresses all AML-related topics, especially Know Your Customer (KYC), ABC, Sanctions & Embargoes and Anti-Fraud.

This document sets out the rules and regulations which must be complied with by all Terrapinn staff.

Prohibited Business Relationships

Terrapinn must refuse to open an account/enter into a relationship or must close an existing account/terminate a relationship, if Terrapinn cannot form a reasonable belief that it knows the true identity of the client and/or UBO (ultimate beneficial owner) and/or the nature of business or formal requirements concerning the identification of the client and/or UBOs are not met.

In particular, Terrapinn will not

  • Accept assets that are known or suspected to be the proceeds of criminal activity
  • Enter into/maintain business relationships with individuals or entities known or suspected to be a terrorist or a criminal organisation or member of such or listed on sanction lists
  • Maintain anonymous accounts, accounts for shell banks or pay-through accounts
  • Enter into relationships with clients from Special Risk Countries or
  • Enter into relationships with clients operating in prohibited industries

Management and Key Controls of AML and AFC Risk

Terrapinn has developed and implemented a comprehensive set of measures to identify, manage and control its AML risk. These measures are, at a group level

  • Annual review of group transactions, looking for evidence of any prohibited business relationships

And at a company level

  • No transactions are to be undertaken with companies or individuals from prohibited countries
  • Payments (including cash remittances) must be made by the contracted party (i.e. no payments are to be accepted from third parties)

Risk Analysis

Terrapinn has an ongoing AML/AFC Risk Analysis to assess the level of risk exposure considering the business’s customers, products, services, entities and geographic locations risk and to derive appropriate security measures from this analysis. AML safeguards are derived from the results of the AML Risk Analysis.

Embargo Program

Compliance with all applicable embargoes is mandatory within Terrapinn and for all Terrapinn employees globally. Each company must comply with the embargo regulations of the country in which the company is domiciled, and in which their bank(s) is(are) domiciled.

All EU embargo regulations are binding for the whole Terrapinn group.

U.S. embargoes generally apply to U.S. persons and any entity, regardless of their place of domicile or work or where organised, and any individual causing activity with the U.S., whether from inside or outside the U.S.

Additionally, each office must comply with the embargo regulations of their bank(s).

Anti-Bribery and Corruption (ABC) and Anti-Fraud

Terrapinn does not tolerate bribery, or any form of corruption. All Terrapinn employees and third parties that act on Terrapinn’s behalf are strictly prohibited from having any involvement in acts of bribery and corruption. Terrapinn staff need to be particularly sensitive to how they interact with public officials and ensure that gifts, entertainments, donations and business courtesies are within acceptable levels.

Record Retention

All data obtained according to client identification and AML security measures must be documented. Records must be kept for a minimum of 5 years, notwithstanding potentially longer retention periods under local civil or commercial law.

Research and Filing of Suspicious Activity Reports (SARs)/Suspicious Transaction Reports

Suspicious activities must be properly handled and escalated within the respective Terrapinn legal entity, to either the managing director or finance manager of the company in question. They in turn have a responsibility to report it to the CFO. This is the responsibility of all Terrapinn staff.

Responsibility for ensuring adherence

In each business, the managing director and finance manager will be responsible for ensuring the full adherence of all staf