1. Policy Statement
Voxmere International Ltd ("Voxmere") is committed to preventing money laundering, terrorist financing, and other financial crimes. This policy sets out the principles, procedures, and controls we maintain to ensure compliance with applicable anti-money laundering ("AML") legislation and international best practice.
As a software consultancy, Voxmere does not operate as a financial institution. However, we recognise our responsibility to conduct business transparently and to ensure that our services are not used to facilitate illicit activity.
2. Regulatory Framework
This policy has been developed with reference to:
- EU Directive 2015/849 (4th Anti-Money Laundering Directive) and subsequent amendments
- Bulgarian Measures Against Money Laundering Act
- Financial Action Task Force (FATF) Recommendations
- Applicable international sanctions regimes
3. Know Your Client (KYC)
Before entering into a business relationship, Voxmere conducts proportionate due diligence to establish the identity and legitimacy of prospective clients. This includes:
- Verification of the legal entity (company registration, certificate of incorporation)
- Identification of the ultimate beneficial owner(s) holding 25% or more of the entity
- Verification of the identity of the authorised representative
- Understanding the nature and purpose of the proposed engagement
- Screening against international sanctions lists and Politically Exposed Persons (PEP) databases
Enhanced due diligence is applied where higher risk factors are identified, including clients in high-risk jurisdictions, complex ownership structures, or unusual engagement patterns.
4. Ongoing Monitoring
We conduct ongoing monitoring of business relationships to ensure that:
- Client information remains current and accurate
- Transaction patterns are consistent with the known nature of the engagement
- Any changes in beneficial ownership or corporate structure are identified and assessed
- Payments are received from expected sources and through legitimate channels
5. Red Flags
Staff are trained to recognise indicators of potential money laundering or terrorist financing, including but not limited to:
- Clients unwilling to provide standard identification documentation
- Requests to invoice through unrelated third-party entities
- Payments from jurisdictions subject to international sanctions
- Unusual urgency or secrecy surrounding an engagement
- Significant overpayments with requests for refunds
- Requests for services with no clear legitimate business rationale
6. Reporting Obligations
Where suspicious activity is identified, Voxmere will:
- Document the concern internally
- Escalate to the designated compliance officer
- File a Suspicious Activity Report (SAR) with the relevant Financial Intelligence Unit where required by law
- Not proceed with the transaction or engagement until the matter has been assessed
It is a criminal offence to tip off a client or third party that a report has been or may be filed.
7. Sanctions Compliance
Voxmere does not engage with individuals or entities subject to sanctions imposed by the European Union, United Nations, OFAC (United States), or HM Treasury (United Kingdom). All clients and beneficial owners are screened prior to engagement and periodically thereafter.
8. Record Keeping
We maintain records of all client due diligence, transaction monitoring, and compliance decisions for a minimum of five years after the end of the business relationship, or as otherwise required by applicable law.
9. Staff Training
All relevant personnel receive training on AML obligations, red flag indicators, and reporting procedures. Training is provided upon onboarding and refreshed annually or when material regulatory changes occur.
10. Compliance Officer
Voxmere has appointed an internal compliance officer responsible for:
- Overseeing the implementation of this policy
- Reviewing and updating AML procedures
- Receiving and assessing internal suspicious activity reports
- Liaising with regulatory authorities as necessary
11. Policy Review
This policy is reviewed at least annually, or more frequently if required by changes in legislation, business activities, or risk assessments. The effective date at the top of this page indicates the most recent revision.
12. Contact
For questions regarding this AML Policy, please contact info@voxmere.xyz.