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AML / KYC Notice

Last updated: January 2026

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