Important Information
III. Conduct & Compliance
AML & Counter-Terrorism Financing
BLACKSWAN HOLDINGS LIMITED applies AML and CTF controls modelled on FATF Recommendations, the EU AMLD, the UK Proceeds of Crime Act 2002 and Money Laundering Regulations 2017, and ADGM AML Rules.
Onboarding
Investors and counterparties undergo identity verification, source-of-funds and source-of-wealth checks, sanctions screening (UN, EU, UK, US OFAC, UAE), and adverse media screening proportionate to risk. Politically exposed persons require additional senior approval.
Ongoing monitoring
Relationships are monitored for the life of the engagement. Material changes in beneficial ownership, jurisdiction, or risk profile trigger refresh procedures. Suspicious activity is reported to the relevant Financial Intelligence Unit.
Refusal
The firm declines to onboard, and may exit, any relationship that cannot be evidenced to its standards or that is inconsistent with sanctions and export-control law. No reasons are required to be given.
