AML/CTF Risk Appetite Policy

  Extract from Heritage Group Kommanditbolag ’s AML/CTF Risk Appetite Policy detailing the Prohibited and Restricted Business activities.

 Purpose and Scope

Heritage Group Kommanditbolag is registered as a professional Trustee and fiduciary management in Sweden.

The organization provides payment services to natural and legal persons. The purpose of this Anti-Money Laundering / Counter Terrorist Financing (“AML/ CTF”) Risk Appetite Policy (the “Policy”) is to define Horizon Group’s risk tolerance and the guiding principles governing Money Laundering and Terrorist Financing (“ML/TF”) risk identification, measurement, reporting, management and monitoring, as required by applicable laws…

 Accepted Business

As a general principle, Heritage Group Kommanditbolag shall not onboard Clients carrying out businesses or activities that are illegal, conducted in absence of required licenses or permissions, or present an excessive reputational risk (which includes any material adverse media).  

Heritage Group Kommanditbolag will not do business with persons, groups, legal entities, bodies, and similar which have been sanctioned for major offenses irrespective of when the Client was sanctioned and the jurisdiction(s) in which it was sanctioned.  

However, in some circumstances the Onboarding Committee may approve such Clients undertaking a Risk Based Approach, depending on the facts and merits of the sanction.

 Prohibited Client Types and Prohibited Payment Flows

Heritage Group Kommanditbolag does not permit pay in or pay outs from its accounts in physical cash. Heritage Group Kommanditbolag does not onboard, nor will it process the payment flows for its PSP Clients, for the following:  

Groups, legal bodies or similar subject to international sanctions or embargoes, in particular as issued by the Commission de Surveillance du Secteur Financier (“CSSF”), HM Treasury (UK),the European Union (“EU”), the United Nations (“UN”) or the US Office of Foreign Assets Control (“OFAC”) and other sanction lists;“Non-standard” or “non transparent” activities – those carried out through special-purpose or assimilated legal entities (special purpose vehicles) (structures) or in jurisdictions that impede transparency or which do not meet international banking standards;  

Bidding fee auctions, penny auctions, or any type of all-pay auction in which all participants must pay a non-refundable fee to place each small incremental bid;  

Shell banks; (banks based in countries where they have no physical presence involving decision-making and management and which are typically not connected to wider regulated financial groups);  

Shell companies; (a company with no physical presence involving effective decision-making, operations or assets other than cash or equivalents of cash);  

Bearer share corporations and companies connected to nominee or similar arrangements for the purpose of hiding or mask the true beneficial ownership (some trust structures may be permitted, depending on the merits of the case and there is no suggestion of untoward behavior);