AML Policy

1.0 Introduction

NAJM Capital Ltd. is fully committed to combating money laundering, terrorist financing, and other financial crimes. The Company has adopted strict internal policies and procedures designed to detect, mitigate, and prevent any suspicious activities associated with its services or clients. NAJM Capital Ltd. continuously monitors its exposure to AML risk and upholds the principles of integrity, accountability, and regulatory compliance.

We believe that understanding our clients thoroughly enables us to effectively manage risks, ensure compliance, and report any unusual or suspicious activity to relevant authorities as required under applicable laws and regulations.

2.0 Know Your Customer (KYC) Client Due Diligence (CDD) Policy

2.1 Client Due Diligence (CDD)

CDD is a fundamental process whereby the Company must:

Confirm the true identity of clients.
Verify whether the client is acting on behalf of another party.
Confirm that there are no legal or sanctions-related barriers to servicing the client.
Understand the nature of the client's business and expected activity.
Assist regulatory or law enforcement bodies with any investigations, where applicable.

CDD measures include:

Identifying and verifying the client’s identity.
Identifying and verifying the Ultimate Beneficial Owner (UBO).
Gathering information on the purpose and intended nature of the business relationship.

2.2 Know Your Customer (KYC)

The KYC process is central to assessing the legitimacy of our clients and preventing financial crime. This includes identity verification and background screening based on international AML standards.

For Natural Persons:

Full Name
Date of Birth
Nationality
Residential Address
Origin of Funds
Occupation and Employer Name

Documents Required:

Valid government-issued photo ID (passport, national ID, or driver’s license)
Proof of address (utility bill, bank statement, or similar – not older than 3 months)

For Legal Entities:

Company Name
Incorporation Number and Date
Country and Registered Address
Ownership Structure, Shareholders, and Beneficial Owners
Directors' Proof of Identity

Documents Required:

Certificate of Incorporation
Memorandum Articles of Association
Proof of registered address
Board Resolution authorizing the account
ID and address proof of directors and UBOs

Failure to provide complete or accurate KYC documentation may lead to account suspension or denial of services.

3.0 Transaction Monitoring

NAJM Capital Ltd. implements robust transaction monitoring systems that review client activity for suspicious patterns or inconsistencies. Our systems incorporate automated tools and manual oversight to detect red flags such as:

Unusually large transactions
Rapid movement of funds
Inconsistencies with stated customer profiles
Transactions from high-risk jurisdictions

Where suspicious activity is identified, NAJM Capital Ltd. will:

Freeze the transaction or account (if necessary)
Conduct internal investigations
Submit a Suspicious Transaction Report (STR) to the appropriate regulatory authority

In cases of confirmed fraud or money laundering, client accounts may be closed, and funds forfeited in accordance with legal procedures.

4.0 Record Keeping

All client-related documents, identification data, transaction records, and STR filings are securely stored and retained for at least 5 years after the termination of the business relationship. These records are available to competent authorities upon lawful request.

5.0 Training and Awareness

All staff members of NAJM Capital Ltd., particularly those in compliance and client-facing roles, are trained on AML/KYC regulations and internal policies. Regular refresher courses and updates are provided to ensure ongoing awareness of emerging risks and regulatory expectations.

6.0 Policy Review and Updates

This AML Policy is reviewed and updated regularly to remain in alignment with evolving laws, regulatory guidelines, and industry best practices. NAJM Capital Ltd. reserves the right to amend this policy without prior notice, where required by law or internal compliance standards.

7.0 Contact

For questions related to AML compliance or to report suspicious activity, please contact:
Email: [email protected]
Registered Address: Christaki Kranou 46, Office 2, Potamos Germasogeias, 4046, Limassol, Cyprus