Know Your Customer (KYC) Policy
Global Unlimited Intertrade LTD
Effective Date: May 13, 2025
1. Introduction
This KYC Policy outlines the principles and procedures adopted by Global Unlimited Intertrade LTD (“the Company”, “we”, “our”) to comply with applicable laws and regulations related to customer due diligence (CDD), anti-money laundering (AML), and countering the financing of terrorism (CFT).
As a responsible business entity registered in Malta, Global Unlimited Intertrade LTD is committed to conducting business with integrity, transparency, and in full compliance with the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) and EU AML directives.
2. Objectives of the KYC Policy
The primary objectives of this KYC Policy are to:
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Prevent the Company from being used for criminal activity, including money laundering and terrorist financing;
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Establish and verify the identity of our customers and beneficial owners;
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Assess and mitigate the risks posed by each customer relationship;
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Maintain comprehensive, up-to-date records of all customers and transactions;
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Ensure continuous monitoring and periodic reviews of customer accounts.
3. Scope of Application
This KYC Policy applies to:
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All customers and clients of Global Unlimited Intertrade LTD;
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Any person or legal entity entering into a business relationship with the Company;
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All employees, agents, and representatives of the Company involved in onboarding, account management, or due diligence processes.
4. Customer Due Diligence (CDD)
4.1 Standard CDD Measures
The following standard CDD procedures are applied:
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Identification and verification of the customer using reliable, independent source documents, data, or information;
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Understanding the nature and purpose of the business relationship;
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Ongoing monitoring of the relationship and transactions.
For individuals:
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Full legal name;
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Date of birth;
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Nationality;
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Residential address;
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Valid identification (e.g., passport, national ID).
For legal entities:
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Company name and registration number;
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Registered address and operational address (if different);
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Directors and shareholders;
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Ultimate Beneficial Owner (UBO) details;
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Certificate of Incorporation;
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Memorandum and Articles of Association.
4.2 Enhanced Due Diligence (EDD)
Enhanced Due Diligence is applied to higher-risk customers or transactions, including but not limited to:
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Politically Exposed Persons (PEPs);
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Customers in high-risk third countries;
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Complex corporate structures or offshore entities;
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Unusually large or suspicious transactions.
EDD may involve:
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Additional verification checks;
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Source of wealth and source of funds documentation;
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Senior management approval for establishing the business relationship;
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Continuous monitoring with increased scrutiny.
5. Risk-Based Approach
The Company applies a risk-based approach (RBA) to KYC and AML, categorizing customers into low, medium, and high-risk profiles based on:
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Geographic location;
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Type of client and business;
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Products and services used;
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Transaction patterns and frequency;
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Delivery channel (e.g., face-to-face vs. online).
Appropriate due diligence and monitoring are applied based on this risk categorization.
6. Ongoing Monitoring
Global Unlimited Intertrade LTD conducts ongoing monitoring to:
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Identify and report suspicious transactions;
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Detect inconsistencies with previously gathered customer information;
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Ensure that documents and data are kept up to date;
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Reassess the customer’s risk rating periodically.
7. Record Keeping
We maintain customer records and due diligence documentation for a minimum of five (5) years after the end of the business relationship or the date of the last transaction.
Records include:
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Identity verification documents;
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Risk assessments;
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Transaction records;
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Communication logs and due diligence findings.
8. Data Protection and Confidentiality
All personal data collected under this policy is processed in accordance with the EU General Data Protection Regulation (GDPR) and the Companyโs Privacy Policy. Data is stored securely and is accessed only by authorized personnel.
9. Reporting Obligations
In compliance with AML laws, Global Unlimited Intertrade LTD is required to:
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Report any suspicious activity to the Financial Intelligence Analysis Unit (FIAU) Malta;
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Cooperate with regulatory and law enforcement authorities;
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Refrain from tipping off the customer under investigation.
10. Staff Training and Awareness
We provide regular training to all relevant employees and representatives to ensure they:
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Understand their KYC/AML responsibilities;
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Can identify and report suspicious activities;
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Stay updated on legal and regulatory developments.
11. Third-Party Reliance and Outsourcing
When working with third parties (e.g., payment providers, business introducers, or due diligence partners), we ensure:
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The third party is regulated and compliant with AML/KYC laws;
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A formal agreement is in place outlining their obligations;
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We retain ultimate responsibility for customer due diligence.
12. Policy Review and Updates
This policy is reviewed annually or whenever significant legal or operational changes occur. Updates are approved by the Companyโs senior management and made available to all relevant stakeholders.
13. Contact Information
For questions regarding this KYC Policy or to report suspicious activity:
Global Unlimited Intertrade LTD
๐ Mosta Road, Central Office Building, Block A, Level 0, Halmann Vella, LJA 9016 Lija, Malta
๐ +44 7514 013350
๐ง office@globalunlimitedintertrade.com
