AML/CFT Compliance

Use of personal data

The information we require includes but not limited to:

• Your full name

• Your date of birth

• Your address

To verify these details, documents such as your passport, driver’s licence, birth certificate, and documents that show your address such as a current bank statement or utility bill will be required.

With relation to a company or trust, we will need information about those entities including the people associated with it (such as directors and shareholders, trustees and beneficiaries). The information may include a constitution, deed, or other information confirming source of funds.

Personal data obtained in the context of AML/CTF is processed by a compliance team using a compliance tool that serves as a record-keeping system designed for the purposes of the prevention, detection or investigation of potential money laundering and terrorist financing. In line with our legal obligations, our processing activities shall allow applying:

• Appropriate client due diligence (CDD) measures for new and existing clients, their ultimate beneficial owners and the client representatives

• A Risk Based Approach (RBA) as the cornerstone of a data driven EPA Business AML/CTF framework

EPA Business will not process personal data obtained in a way that is incompatible with the AML/CTF purposes without consent from individuals to do so.

Before we start working for you, we will let you know what information we need, and what documents you need to show us.

We will not disclose personal information provided by you to any third parties, except where authorised by law. Examples include supplying information to other government agencies for law enforcement purposes where the other agency has a property interest in receiving the information.

Data retention

For client relationships ended as from 2020, data will be kept for 10 years.