Anti-Money Laundering (AML) Policy Statement

Last Updated: April 2026

1. Introduction

Core Trade Finance Limited (“we,” “us,” or “our”) is committed to the highest standards of anti-money laundering (AML), counter-terrorist financing (CTF), and anti-fraud compliance. We recognise that as a business operating in the international trade finance sector, we have a responsibility to ensure that our services are not used, directly or indirectly, for the purposes of money laundering, terrorist financing, fraud, sanctions evasion, or any other form of financial crime.

This AML Policy Statement sets out our public commitment to financial crime prevention and outlines the framework we operate within to ensure that all transactions conducted through Core Trade Finance Limited are legitimate, transparent, and fully compliant with applicable laws and regulations.

2. Legal and Regulatory Framework

Core Trade Finance Limited operates in full compliance with the following applicable laws, regulations, and international standards:

  • Proceeds of Crime Act 2002 (POCA) — the primary UK legislation governing money laundering offences and the obligation to report suspicions of money laundering
  • Terrorism Act 2000 — governing counter-terrorist financing obligations
  • Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 — setting out the due diligence and reporting obligations for businesses in the regulated sector
  • Sanctions and Anti-Money Laundering Act 2018 — governing the UK’s sanctions regime post-Brexit
  • Financial Action Task Force (FATF) Recommendations — the internationally recognised standards for AML and CTF compliance
  • Wolfsberg Group Principles — internationally recognised guidance for financial institutions on AML, KYC, and correspondent banking standards
  • UK Office of Financial Sanctions Implementation (OFSI) Guidelines — governing compliance with UK financial sanctions
  • United Nations Security Council Sanctions — applicable international sanctions regimes

Core Trade Finance Limited monitors regulatory developments continuously and updates its internal policies and procedures accordingly to ensure ongoing compliance.

3. Our Commitment

Core Trade Finance Limited is firmly committed to:

  • Ensuring that our business is not used as a vehicle for money laundering, terrorist financing, fraud, or any other form of financial crime
  • Conducting thorough due diligence on all clients, transactions, and counterparties before providing any service
  • Maintaining robust internal controls, policies, and procedures designed to detect, prevent, and report financial crime
  • Cooperating fully with law enforcement agencies, regulatory authorities, and financial intelligence units where required by law
  • Refusing to engage with any client, transaction, or counterparty that presents an unacceptable risk of financial crime
  • Training and maintaining awareness among all relevant personnel on AML and CTF obligations
  • Continuously reviewing and improving our AML framework in line with evolving regulatory requirements and industry best practice

4. Know Your Customer (KYC) and Client Due Diligence (CDD)

Core Trade Finance Limited applies a rigorous Know Your Customer (KYC) and Client Due Diligence (CDD) process to all clients prior to the provision of any service. Our due diligence process includes but is not limited to:

Standard Due Diligence — applied to all clients:

  • Verification of the client’s identity and legal existence
  • Collection and verification of Certificate of Incorporation and company registration documents
  • Identification and verification of principal shareholders and beneficial owners
  • Collection of passport copies and National Identity documents of principal shareholders and directors
  • Verification of the client’s registered address and principal place of business
  • Assessment of the nature and purpose of the proposed transaction
  • Review of the client’s bank statements and financial standing where applicable
  • Screening against international sanctions lists, politically exposed persons (PEP) databases, and adverse media sources

Enhanced Due Diligence (EDD) — applied in higher risk situations:

Where a client, transaction, or jurisdiction presents a higher risk of money laundering or terrorist financing, Core Trade Finance Limited will apply Enhanced Due Diligence measures. Circumstances that may trigger EDD include but are not limited to:

  • Clients or transactions involving high-risk jurisdictions as identified by FATF
  • Clients identified as Politically Exposed Persons (PEPs) or their close associates
  • Transactions that are unusually large, complex, or lack an apparent legitimate purpose
  • Clients or beneficiaries operating in sectors with elevated financial crime risk
  • Any other circumstances that give rise to a higher risk assessment

Core Trade Finance Limited reserves the right to request additional documentation or information at any stage of the client relationship where it considers this necessary for due diligence purposes, and to decline or terminate any engagement where satisfactory due diligence cannot be completed.

5. Sanctions Screening

Core Trade Finance Limited screens all clients, beneficiaries, counterparties, and transactions against the following sanctions lists prior to and throughout the course of any engagement:

  • UK HM Treasury Consolidated Sanctions List
  • United Nations Security Council Sanctions List
  • European Union Sanctions List
  • Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List
  • Any other applicable sanctions regimes relevant to the jurisdiction of the client or transaction

Core Trade Finance Limited will not engage with any individual, entity, or jurisdiction that is subject to applicable financial sanctions. Any potential sanctions match identified during screening will be escalated immediately and the transaction will be suspended pending investigation.

6. Suspicious Activity Reporting

Core Trade Finance Limited maintains robust internal procedures for the identification, escalation, and reporting of suspicious activity. Where we have knowledge or reasonable suspicion that a transaction may involve money laundering, terrorist financing, or any other financial crime, we are legally obliged to submit a Suspicious Activity Report (SAR) to the UK National Crime Agency (NCA) via the NCA’s online reporting system.

In accordance with applicable legislation, Core Trade Finance Limited will not disclose to any client or third party that a SAR has been submitted or that an investigation is underway, as such disclosure may constitute a “tipping off” offence under the Proceeds of Crime Act 2002.

7. Record Keeping

Core Trade Finance Limited maintains comprehensive records of all client due diligence documentation, transaction records, and compliance activities in accordance with applicable legal requirements. Specifically:

  • KYC and client due diligence records are retained for a minimum of five years following the end of the business relationship, in accordance with the Money Laundering Regulations 2017
  • Transaction records are retained for a minimum of five years from the date of the transaction
  • SAR records and related documentation are retained in accordance with NCA guidance

All records are stored securely with access restricted to authorised personnel only.

8. Risk-Based Approach

Core Trade Finance Limited adopts a risk-based approach to AML and CTF compliance, as required by the Money Laundering Regulations 2017. This means that we assess the level of risk associated with each client, transaction, and business relationship and apply proportionate due diligence measures accordingly. Our risk assessments take into account the following factors:

  • The nature and purpose of the transaction
  • The jurisdiction of the client, beneficiary, and counterparty
  • The type of financial instrument requested
  • The client’s business sector and ownership structure
  • The source of funds and source of wealth
  • Any PEP status or adverse media findings
  • Any prior suspicious activity or compliance concerns

Our risk assessments are reviewed and updated throughout the course of each client relationship and transaction.

9. Prohibited Activities

Core Trade Finance Limited strictly does not engage in, facilitate, or knowingly assist with any of the following:

  • Money laundering or the concealment of proceeds of crime
  • Terrorist financing or the financing of proliferation of weapons of mass destruction
  • Sanctions evasion or dealings with sanctioned individuals, entities, or jurisdictions
  • Fraud, misrepresentation, or the use of false documentation
  • “SBLC leasing,” “SBLC purchase,” “SBLC funding,” “monetisation of bank instruments,” or “investment against bank guarantee” — these are not legitimate trade finance practices and are commonly associated with financial fraud
  • Any transaction that lacks a clear and legitimate commercial purpose
  • Any activity that would constitute a financial crime under applicable UK or international law

Any client found to be engaged in any of the above activities will have their engagement terminated immediately and the matter reported to the relevant authorities without prior notification to the client.

10. Internal Controls and Governance

Core Trade Finance Limited maintains a framework of internal controls designed to prevent and detect financial crime. This framework includes:

  • Clear policies and procedures governing client onboarding, due diligence, transaction monitoring, and suspicious activity reporting
  • Designated responsibility for AML and CTF compliance within the organisation
  • Regular review and update of internal AML policies and procedures to reflect changes in applicable laws, regulations, and industry best practice
  • Ongoing monitoring of client relationships and transactions throughout the course of each engagement
  • Maintenance of a culture of compliance and zero tolerance for financial crime at all levels of the organisation

11. Third Party Reliance

Where Core Trade Finance Limited relies on third parties such as introducers, brokers, or business partners for the referral of clients, we maintain ultimate responsibility for ensuring that appropriate due diligence has been conducted on all referred clients. Core Trade Finance Limited does not outsource its AML obligations and retains full responsibility for compliance regardless of the source of the client introduction.

12. Non-Compliance and Consequences

Core Trade Finance Limited takes a zero-tolerance approach to financial crime. Any client, counterparty, or third party found to have provided false information, misrepresented their identity or the nature of a transaction, or engaged in any form of financial crime in connection with our services will face the following consequences:

  • Immediate termination of the business relationship
  • Forfeiture of any fees paid where permitted by law
  • Reporting to the NCA, OFSI, or any other relevant regulatory or law enforcement authority
  • Potential civil or criminal legal action where appropriate

13. Contact and Reporting

If you have any concerns regarding potential financial crime, suspicious activity, or misuse of our services, or if you wish to verify the legitimacy of any communication or offer made in our name, please contact us immediately at:

Core Trade Finance Limited 14/2E, Docklands Business Centre, 10-16 Tiller Road, London, E14 8PX, United Kingdom

Email: [email protected] Website: www.coretradefinance.com

Core Trade Finance Limited is committed to responding to all compliance-related enquiries promptly and in accordance with our legal obligations.

14. Policy Review

This AML Policy Statement is reviewed and updated regularly to reflect changes in applicable laws, regulations, and industry best practice. The most recent version of this policy will always be published on this page with an updated revision date.