AML / KYC Notice
Celebut Limited is committed to full compliance with global Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) regulations, including:
- FATF recommendations
- EU AML directives
- UK Money Laundering Regulations
- FinCEN requirements (where applicable)
- Local AML/CFT laws in relevant jurisdictions
AML/CFT Policy
Celebut Limited maintains a global AML/CFT compliance framework aligned with FATF recommendations and national AML statutes. The policy covers governance, KYC/EDD processes, sanctions screening, transaction monitoring, SAR/STR reporting, internal controls, training, and record-keeping.
This policy establishes internal controls and procedures to prevent Celebut from being used for money laundering, terrorist financing, fraud, or other financial crimes.
(a) Scope
This policy applies to:
- All Celebut Limited platform users/employees
- Senior management
- Compliance teams
- Contracted agents performing KYC/verification
- Platform users utilising wallet features
(b) AML Governance Structure
- Board of Directors
- Provides oversight and approves AML/CFT policies.
- AML Compliance Officer (MLRO)
Responsibilities include:
- Oversight of AML program
- Filing STR/SAR reports
- Managing audits
- Liaising with regulators
- Maintaining training programmes
(c) Compliance Team
- Conduct ongoing monitoring
- Perform KYC reviews
- Conduct sanctions screening
- Investigate suspicious activity
(d) Customer Due Diligence (CDD)
- Standard Verification
Required for all users accessing wallet services:
- Government-issued ID
- Selfie/biometric match
- Proof of address
- Date of birth validation
- Database checks
(e) Enhanced Due Diligence (EDD)
Triggered when:
- User is a PEP (Politically Exposed Person)
- User is from a high-risk jurisdiction
- Multiple large transactions occur
- Adverse media is detected EDD measures include:
- Enhanced identity verification
- Additional source-of-funds checks
- Transaction limit reductions
- Ongoing monitoring
(f) Simplified Due Diligence
May apply where legal exemptions are present (e.g., low-risk accounts).
(g) Sanctions Compliance
Celebut screens all users against :
- UN sanctions list
- OFAC SDN
- EU consolidated lists
- UK HMT sanctions
Matches are escalated immediately.
- Ongoing Monitoring
- Transaction Monitoring
All wallet activity is monitored for:
- Structuring/smurfing
- High-velocity transactions
- Unusual account behaviour
- Transfers to/from high-risk locations
- Use of multiple devices/IP anomalies Automated systems flag transactions for review.
(h) Behavioral Monitoring
Monitoring includes:
- Social media behaviour linked to illicit promotion
- Fraud indicators (scams, impersonation, phishing)
- Sudden changes in engagement patterns
(i) Suspicious Activity Reporting (SAR/STR)
Celebut must:
- File SAR/STR reports to relevant authorities promptly
- Maintain confidentiality of reporting
- Prohibit “tipping off” users
(j) Record Keeping
Celebut retains:
- KYC documents: minimum 5 years after account closure
- Transaction records: 5–7 years
- Internal logs: per statutory guidelines
- SAR/STR reports: per regulatory requirements