AML Policy

Centrino Capital is committed to the highest standards of compliance against money laundering (AML) and anti-terrorist financing (ATF). The objective of the Company’s Policy against Money Laundering and Terrorism Financing is to actively prevent the risks associated with these activities.

To help the government combat the financing of terrorism and money laundering activities, the law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. We have an obligation to report suspicious client activity relevant to money laundering.

Money Laundering

Money laundering is the process of converting funds received from illegal activities (such as fraud, corruption, terrorism, etc.) into other funds or investments that appear legitimate to hide or distort the actual source of funds.

The money laundering process can be divided into three sequential stages:

1. Placement

Any withdrawal of funds from your Centrino Capital account to a bank account can only be refunded to the same bank account from which the funds were originally received or to another bank account under the client’s individual name.
Please note that the processing time of withdrawals depends on the currency of the bank account, as well as the location and internal policies and procedures of the recipient’s financial institution and country. Expected timelines: 2 to 7 business days.

2. Layering

The funds are transferred or moved to other accounts and financial instruments to disguise the origin and break the traceability of the entity carrying out the transactions. This step makes it more difficult to follow the money trail.

3. Integration

The funds are reintroduced into the economy as legitimate funds through the purchase of goods and services.
Centrino Capital adheres to Anti-Money Laundering principles and actively prevents any action that targets or facilitates the legalization of illegally obtained funds. The AML policy prevents the use of the company’s services for money laundering, terrorist financing, or other criminal activity.

Cash Transactions

To prevent money laundering, Centrino Capital does not accept or pay in cash under any circumstances. The company reserves the right to suspend any client activity that may be considered illegal or, in the opinion of the staff, related to money laundering.

Company Procedures

Centrino Capital will ensure that it is dealing with a real and legal person. The company performs all necessary measures in accordance with applicable laws and regulations issued by monetary authorities.

The AML policy is implemented within Centrino Capital by the following means:

  • Know Your Client (KYC) policy and due diligence

  • Monitoring customer activity

  • Registry maintenance

Know Your Customer (KYC)

Due to Centrino Capital’s commitment to AML and KYC policies, each customer must complete a verification procedure. Before any cooperation begins, the company ensures satisfactory proof of identity of the client or counterparty.

The company applies increased scrutiny to clients who are residents of countries identified by credible sources as having inadequate AML standards or who may pose a high risk of crime and corruption.

For Individual Clients:

During registration, each client must provide personal information:

  • Full Name

  • Date of Birth

  • Country of Origin

  • Full Residential Address

Required Documents:

  • Valid passport (first page showing photo and signature), or

  • Driving license with photograph, or

  • National ID card (front and back)

  • Proof of address (e.g., utility bills or bank statements, not older than 3 months)

If the documents are not in Latin characters, a notarized English translation must be provided.

For Corporate Clients:

If the applicant company is listed on a recognized or approved stock exchange, or there is independent evidence showing it is a wholly owned subsidiary, no further steps are usually required.

If the company is not listed, and none of the main directors or shareholders already have an account with Centrino Capital, the following documentation is required:

  • Certificate of Incorporation or equivalent

  • Memorandum and Articles of Association or equivalent

  • Certificate of Good Standing or proof of registered address

  • Board Resolution to open an account and authorization of signatories

  • Copies of Powers of Attorney or other authorities granted

  • Proof of identity of directors dealing with Centrino Capital (as per individual KYC rules)

  • Proof of identity of the ultimate beneficial owner(s) or controlling person(s)

Tracking Customer Activity

In addition to collecting customer information, Centrino Capital monitors all client activity to identify and prevent suspicious transactions.
A suspicious transaction is one that is inconsistent with the client’s legitimate business or transaction history.
Centrino Capital uses both automated and manual monitoring systems to detect and prevent illegal use of its services.

Registry Maintenance

Records must be kept of:

  • All transaction data and identification information

  • All documents related to money laundering issues (e.g., suspicious activity reports, AML monitoring records, etc.)

These records are retained for a minimum of 7 years after the account is closed.

Measures Taken

In cases where Centrino Capital suspects a transaction is related to money laundering or other criminal activity, it will act in accordance with applicable law and report the suspicious activity to the relevant regulatory authority.

Centrino Capital reserves the right to suspend or block any client account deemed suspicious or terminate a relationship with an existing customer at its sole discretion.

For more information, you can contact us at support@centrinocapital.org