AML, KYC & sanctions policy

CSM Trading Consulting & Services LLC is committed to preventing money laundering, terrorist financing and sanctions evasion, and to working only with legitimate businesses.

Customer due diligence

• Verification of company registration and beneficial owners (25%+).
• Government ID verification of directors and authorized signatories.
• Understanding of the nature and purpose of each business relationship.
• Enhanced due diligence for higher-risk clients and politically exposed persons.

Sanctions screening

Clients and counterparties are screened against OFAC (SDN), EU and UN sanctions lists. We do not do business with sanctioned persons or in comprehensively sanctioned jurisdictions.

Prohibited activities

We do not accept clients or transactions involving weapons, illegal drugs, gambling, adult content, unlicensed financial services, shell arrangements without economic substance, or cryptocurrency exchange activities.

Payments

All payments are made to and from accounts in the company's name, against invoices for documented services. We do not accept cash or third-party payments.

Monitoring & record keeping

Transactions are monitored for consistency with the client profile. Records are retained for at least five years. Suspicious activity is escalated and reported to the competent authorities where required.

Responsibility

The company's managing member, Christopher Schmölz, is responsible for this policy, which is reviewed at least annually. Questions: info@csm-trading.com.