1. Statement of commitment

Apex Euro Capital operates a strict zero-tolerance approach to money laundering, terrorism financing, proliferation financing, bribery, corruption, tax evasion and sanctions breaches. Our AML/CFT programme is designed to meet the requirements of EU Directives 2015/849 and 2018/843 (4th and 5th AMLD), Regulation (EU) 2024/1624 (AMLR), Belgian AML Law of 18 September 2017, the FATF 40 Recommendations and applicable jurisdictional rules in every country where we operate.

2. Governance and accountability

Board-level accountability with formal annual approval of the AML/CFT programme.
A designated Money Laundering Reporting Officer (MLRO) with sufficient seniority and independence.
An independent Compliance function reporting directly to the Board Risk Committee.
Three-lines-of-defence model (business, compliance/risk, internal audit).
Mandatory annual AML training and assessment for all staff and contractors.

3. Risk-based approach

We apply a documented risk-based methodology covering client, product, geographic, delivery-channel and transaction risk. Each business relationship and occasional transaction is risk-rated and subject to controls proportionate to the assessed risk level, with annual enterprise-wide risk assessments reviewed by the Board.

4. Customer due diligence (CDD)

Identification and verification of customers, authorised representatives and ultimate beneficial owners (≥25% or control).
Understanding of the purpose and intended nature of the business relationship.
Source-of-funds and source-of-wealth documentation for relevant thresholds.
Sanctions, PEP and adverse-media screening at onboarding and continuously.
Ongoing monitoring of transactions and periodic CDD refresh based on risk rating.

5. Enhanced due diligence (EDD)

EDD is applied for higher-risk situations including: politically exposed persons and their close associates; clients connected to high-risk third countries listed by the European Commission or FATF; complex or unusually large transactions; non-resident clients; cash-intensive businesses; private banking and certain crypto-asset activities. EDD requires senior management approval and additional source-of-wealth verification.

6. Sanctions compliance

Apex screens all clients, beneficial owners, counterparties and transactions against EU, UN, OFAC (US), HMT (UK) and other relevant sanctions lists in real time. We do not engage in transactions involving sanctioned persons, entities or jurisdictions, and we maintain controls to prevent circumvention of sanctions through third parties.

7. Transaction monitoring

Automated and manual monitoring covers transaction patterns, thresholds, structuring indicators, geographic risk factors and behavioural anomalies. Alerts are triaged by the Compliance team and escalated for investigation where warranted.

8. Suspicious activity reporting

Where a member of staff knows, suspects or has reasonable grounds to suspect money laundering or terrorism financing, an internal report is filed with the MLRO. The MLRO assesses the report and, where appropriate, files a Suspicious Activity Report with the Belgian Financial Intelligence Processing Unit (CTIF-CFI) or the competent FIU in the relevant jurisdiction. We strictly observe tipping-off prohibitions.

9. Record-keeping

All CDD records, transaction records and supporting documents are retained for a minimum of 10 years after the end of the business relationship, in line with EU AMLD and Belgian AML Law.

10. Training and awareness

Mandatory induction training within 30 days of joining.
Annual refresher training tailored to role and risk exposure.
Targeted training on emerging typologies (crypto-assets, trade-based ML, sanctions evasion).

11. Independent testing and audit

The AML/CFT programme is subject to independent internal audit on a risk-based cycle and may be reviewed by external assurance providers and our regulators.

12. Contact

AML-related enquiries: compliance@apexeurocapital.com
Whistleblowing: whistleblowing@apexeurocapital.com (handled under EU Whistleblower Directive 2019/1937)

Anti-Money Laundering Policy