Ethos AML Policy



These are the Anti-Money Laundering (AML) Policy and Procedures adopted by PTE (“Ethos”) Ethos is dedicated to building an open, safe and fair financial ecosystem that is compliant with any applicable Money Laundering, Terrorist Financing or similar criminal activity.  Ethos will actively prevent and take measures to guard against being used as a medium for money laundering activities and terrorism financing activities or any other activity that facilitates money laundering or the funding of terrorist or criminal activities.

To these ends:

  • The identities of all new and existing partners will be verified to a reasonable level of certainty
  • Any suspicious activity will be reported, and all AML activities recorded
  • Officers of the organization shall collectively coordinate the AML policies and procedures of Ethos.
  • Ethos shall strive to work with partners and businesses that adopt stringent AML and KYC policies and procedures.



Ethos will conduct due diligence and have a Know-Your-Partner (KYC) policy for employees and contractors as well as any partner, business partner or counter-party (“partners”) and other business entities. This will also include directors and shareholders with a stake holding of 25% or more of Ethos or related entities, as well as every board member. Identities will be verified either online or face-to face or by a combination of both.

When acting as a counter-party for a transaction with an individual, Ethos will require identity verification with a valid government-issued document. This will be either a passport, driver’s license, or government issued document featuring a matching photograph of the individual, and a full name and date of birth matching those provided.

When conducting business with another business entity, Ethos will only interact with established and reputable businesses in good standing that also have stringent KYC and AML policies. If any business fails to provide reasonable certainty that it is duly organized, in good standing or without established KYC and AML policies, Ethos will not establish a business relationship or proceed with any transaction.

If a potential or existing partner either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, Ethos shall refuse to commence a business relationship or proceed with the transaction requested.


Ethos will take a risk-based approach in monitoring its financial activities and that of its partners.

Ethos will actively not accept high-risk partners that are identified as follows:

  • Businesses that regularly handle large amount of cash (i.e. involving $10,000 USD or more) or complex unusually large transactions.
  • Businesses based in or conducting business in or through, a high-risk jurisdiction, or a jurisdiction with known higher levels of corruption, organized crime or drug production/distribution.
  • Situations where the source of funds cannot be easily verified.
  • Unusual patterns of transactions that have no apparent economic or visible lawful purpose.
  • Money sent to or received from areas known to have high levels of criminality or terrorist activity.

Ethos will conduct ongoing monitoring of business relationships with partners, to ensure that the documents, date or information held evidencing the customer’s identity are kept up to date.

The following are examples of changes in a partner situation that may be considered suspicious:

  • A sudden increase in business from an existing customer;
  • Uncharacteristic transactions which are not in keeping with the customer’s known activities;
  • Peaks of activity at particular locations or at particular times;
  • Unfamiliar or untypical types of customer or transaction.

Whenever there is cause for suspicion, the partner will be asked to identify and verify the source or destination of the transactions, whether they be individuals or company beneficial owners.

No action need be taken if there is no cause for suspicion.


Ethos shall maintain internal controls to ensure that all transactions are approved by management, recorded and journaled using enterprise-grade accounting software.


Ethos management will regularly monitor the following procedures to ensure they are being carried out in accordance with the AML policies and procedures of Ethos:

  • partner identity verification;
  • reporting suspicious transactions;
  • record keeping.

Changes will be made to the AML policies and procedures of Ethos when appropriate to ensure compliance.


If Ethos identities suspicious activities, a Suspicious Activity Report (SAR) will be made to criminal authorities as soon as the knowledge or suspicion that criminal activities exist arises.


Records of any identity checks will be maintained for up to 5 years after the termination of Ethos relationship or 5 years from the date when the transaction was completed. Ethos will ensure that all documents, data or information held in evidence of customer identity are kept up to date.

All records will be handled in confidence, stored securely, and will be capable of being retrieved without undue delay.