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🛡️ Anti-Money Laundering (AML) Policy

Effective Date: April 25, 2025

At Evermount Capital, we are committed to the highest standards of anti-money laundering (AML) compliance and ethical behavior. This AML Policy outlines our responsibilities and how we detect, prevent, and report money laundering activities.

  1. Purpose: To prevent the use of our platform for laundering money, financing terrorism, or other financial crimes.
  2. Scope: This policy applies to all users, employees, vendors, and partners of Evermount Capital.
  3. Risk-Based Approach: We apply appropriate due diligence based on user risk profile, location, and transaction behavior.
  4. Customer Identification (KYC): We require identity verification, proof of address, and in some cases, source of funds.
  5. Ongoing Monitoring: We monitor transactions to identify patterns that may indicate suspicious activity.
  6. Suspicious Activity Reporting: All detected red flags are escalated to our AML compliance officer for action.
  7. Sanctions Screening: We screen users and transactions against global sanctions lists and watchlists.
  8. Record Keeping: All identification and transaction records are securely stored for a minimum of 5 years.
  9. Training: Our team receives regular training on AML regulations and red flag indicators.
  10. Cooperation with Authorities: We collaborate with financial regulators and law enforcement when required.
  11. Technology & Tools: We use AI-based transaction monitoring and automated flagging systems.
  12. Politically Exposed Persons (PEPs): Extra scrutiny is applied to users identified as PEPs or linked individuals.
  13. Third-Party Integrations: All APIs and partners undergo risk assessments and must comply with AML obligations.
  14. Non-Face-to-Face Onboarding: Enhanced KYC procedures apply for digital onboarding and remote verifications.
  15. Data Privacy: User data is protected in accordance with our Privacy Policy and applicable data laws.
  16. Funds Freezing: Suspected illicit funds may be frozen pending investigation or regulatory direction.
  17. Tipping Off: Staff are trained never to inform users when an AML investigation is ongoing.
  18. Geographic Risk Controls: Extra measures apply to users from high-risk jurisdictions (FATF-listed countries).
  19. Transaction Limits: Limits may be enforced depending on verification status and behavior.
  20. Escalation Procedures: Internal workflows ensure rapid response to confirmed or suspected violations.
  21. Audits & Reviews: Our AML processes are audited periodically to ensure compliance and effectiveness.
  22. Regulatory Framework: We follow the FATF, SEC, EU AMLD, and Kenyan AML guidelines.
  23. Crypto Compliance: Where applicable, we monitor and analyze blockchain transactions.
  24. Beneficial Ownership: We identify ultimate beneficial owners of accounts, especially for institutions.
  25. Whistleblower Protection: Employees can report suspicious activity anonymously and without retaliation.
  26. AML Officer Contact: Direct reports can be made to compliance@evermount.com.
  27. Automated Suspicion Flags: Patterns like structuring, unusual volumes, or rapid movement are flagged.
  28. Source of Wealth Checks: May be required based on deposit behavior or institutional onboarding.
  29. Client Classification: Users are classified by risk category upon onboarding and reviewed periodically.
  30. Enforcement: Breach of AML policy can lead to suspension, closure, or legal escalation.