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AML and KYC policy

Last updated: 1 September 2026

1. Purpose

This policy describes Silvaland’s Know Your Customer (KYC) and Anti-Money Laundering (AML) / Counter-Terrorist Financing (CFT) procedures to comply with Latvian law and international standards (FATF recommendations).

Silvaland operates under:

  • Latvian Law on the Prevention of Laundering of Proceeds from Crime and Terrorist Financing (No. 64, 2008)
  • EU AML Directive (2015/849/EU, amended by 2018/843/EU)
  • FATF Recommendations
  • Latvian Financial and Capital Market Commission (FCMC) guidelines

3. Know Your Customer (KYC)

3.1 Mandatory KYC Requirements

Before investing, all customers must provide:

Personal Information:

  • Full legal name (as shown in ID)
  • Date of birth
  • Nationality / citizenship
  • Residential address (current and complete)

Identity Verification:

  • Copy of government-issued ID (passport, national ID card, or driving license)
  • Proof of address (utility bill, bank statement, or official letter dated within 3 months)

Financial Information:

  • Tax identification number (or equivalent in your country)
  • Tax residence country
  • Source of investment funds (employment, business, inheritance, savings, etc.)

Beneficial Ownership:

  • If you are a legal entity (company, trust), identify ultimate beneficial owners (>25% stake)

3.2 Enhanced Due Diligence (EDD)

For higher-risk customers, Silvaland may request additional information:

  • Detailed source of funds documentation (bank statements, business records)
  • Explanation of business activities or income sources
  • International transaction history
  • Additional identity documents or references

Higher-risk profiles include:

  • Large investments (> €100,000)
  • Customers from high-risk jurisdictions
  • Politically Exposed Persons (PEPs)
  • Complex corporate structures

3.3 Ongoing KYC

Silvaland periodically reviews customer information to ensure:

  • Data remains current and accurate
  • No changes in beneficial ownership
  • No new risk indicators have emerged

4. Sanctions & PEP Screening

4.1 Sanctions Screening

Before accepting an investment, Silvaland screens customers against:

  • EU sanctions lists (CFSP sanctions, consolidated list)
  • UN sanctions lists (Security Council resolutions)
  • US OFAC sanctions lists (SDN list)
  • Latvian Ministry of Foreign Affairs sanctions

Customers on these lists are rejected.

4.2 PEP Screening

Politically Exposed Persons (PEPs) — those with prominent public functions or close family — may be subject to enhanced due diligence:

  • Additional identity verification
  • Beneficial ownership confirmation
  • Source of funds clarification
  • Enhanced monitoring

5. Anti-Money Laundering (AML) Procedures

5.1 Transaction Monitoring

Silvaland monitors transactions for suspicious activity:

  • Large deposits or withdrawals (>€50,000 single transaction)
  • Rapid sequences of deposits and withdrawals
  • Transactions inconsistent with customer profile
  • Unusual geographic or counterparty patterns

5.2 Suspicious Activity Reporting

If Silvaland detects suspicious activity, we:

  1. Freeze the transaction pending investigation
  2. Document the suspicious pattern
  3. Report to the Latvian Financial Intelligence Unit (FIU) if applicable
  4. Do NOT alert the customer (to avoid “tipping off”)
  5. Maintain confidentiality of the report

Reporting Threshold: Transactions or patterns suggesting possible money laundering, terrorist financing, or other financial crimes.

5.3 Reporting Timeline

Reports to the FIU are submitted immediately upon detection of suspicious activity.

6. Customer Due Diligence (CDD)

6.1 Risk Assessment

Silvaland assesses risk by:

  • Customer type: Individual, company, trust, politically exposed
  • Investment size: Larger investments = higher scrutiny
  • Geographic location: Higher-risk jurisdictions warrant more verification
  • Source of funds: Employment vs. inheritance vs. business income
  • Transaction patterns: Consistent or erratic

6.2 Risk Categories

  • Low-risk: Individual resident in EU country, modest investment, clear source of funds
  • Medium-risk: International customer, large investment, complex source
  • High-risk: Politically exposed person, high-risk jurisdiction, suspicious pattern, complex structure

Each category receives appropriate KYC & monitoring.

7. Business Relationships & Beneficial Ownership

7.1 Beneficial Ownership Definition

A beneficial owner is any natural person who ultimately:

  • Owns or controls (> 25%) a customer entity
  • Exercises control through other means (voting rights, board seats, contracts)
  • Is a beneficiary of a trust or foundation

7.2 Beneficial Ownership Verification

For corporate customers, Silvaland requires:

  • Corporate registration certificate
  • List of shareholders/owners >25%
  • Identification documents for each beneficial owner
  • Board member and signatory information
  • Organizational chart (if complex)

8. Record Keeping

Silvaland maintains records of:

  • All KYC documents and verification results
  • Customer identification and beneficial ownership information
  • Transaction records and suspicious activity reports
  • Communications and decision logs

Retention period: 5 years after account closure or final transaction (Latvian AML law)

9. Politically Exposed Persons (PEPs)

9.1 Definition

PEPs are individuals who hold or have held prominent public functions, including:

  • Government officials (ministers, deputies, judges)
  • Senior military or police officers
  • Central bank governors
  • Senior managers of international organizations
  • Family members or close associates of PEPs

9.2 PEP Screening

Before onboarding, Silvaland checks:

  • International PEP databases (World Check, Refinitiv, etc.)
  • Latvian government official registries
  • EU PEP lists

9.3 PEP Handling

  • PEPs identified during screening undergo enhanced due diligence
  • Source of funds must be clearly documented
  • Investment amounts may be restricted
  • Ongoing monitoring is increased

10. High-Risk Jurisdictions

Silvaland applies enhanced due diligence to customers from countries on:

  • FATF Grey List (countries with AML/CFT deficiencies)
  • EU High-Risk List (identified by European Commission)
  • Latvian Financial Crime List (identified by FCMC)

Customers from these jurisdictions must provide:

  • Clear business explanation
  • Detailed source of funds
  • International transaction history
  • Additional identity documentation

11. Refusal & Account Termination

Silvaland may refuse service to or terminate accounts of:

  • Customers who fail KYC verification
  • Sanctioned individuals or entities
  • Customers engaged in suspicious activity
  • Customers providing false or misleading information
  • PEPs with unclear source of funds
  • Customers from high-risk jurisdictions with insufficient documentation

Notification: Account refusal or termination will be communicated to the customer; reasons may be limited due to AML confidentiality.

12. Staff Training

All Silvaland staff involved in customer onboarding or transaction monitoring receive:

  • Annual AML/CFT training
  • Documentation and record-keeping procedures
  • Sanctions screening and PEP identification
  • Suspicious activity detection and reporting
  • Data protection and confidentiality

13. Compliance Officer

Silvaland appoints a Compliance Officer responsible for:

  • Overseeing AML/CFT procedures
  • Customer due diligence and sanctions screening
  • Suspicious activity investigation and reporting
  • Staff training and documentation
  • Regulatory liaison and audit cooperation

Compliance Contact: compliance@silvaland.eu

14. Third-Party Service Providers

Silvaland conducts due diligence on third-party providers (payment processors, valuation firms, advisors) to ensure they:

  • Have appropriate AML/CFT controls
  • Comply with EU and Latvian law
  • Do not facilitate financial crime

15. Regulatory Cooperation

Silvaland cooperates fully with:

  • Latvian Financial Intelligence Unit (FIU)
  • Financial and Capital Market Commission (FCMC)
  • Tax authorities
  • Law enforcement agencies (upon legal request)
  • International regulators (mutual legal assistance)

16. Customer Privacy

Information collected for AML/KYC purposes is:

  • Used exclusively for compliance
  • Protected under GDPR and AML law confidentiality
  • Not disclosed to third parties except as required by law
  • Retained per legal requirements

See our Privacy Policy

17. Questions?

If you have questions about Silvaland’s AML/KYC procedures:
Email: compliance@silvaland.eu

Last updated: 1 September 2026

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