Anti-Money-Laundering Policy

DRAFT — this document is pending legal review.

Effective date: pending legal review (draft).

SotoWorks S.L. provides professional business address services and, as such, is an obliged entity under Spanish Law 10/2010 of 28 April on the prevention of money laundering and terrorist financing. This policy summarises our obligations and what we expect from our customers.

1. Obliged entity

SotoWorks S.L., with registered office at Sotovilla II, Av. del Conchudo, local 4, 11360 Sotogrande, Cádiz, España and tax ID (CIF) B93650752 (company tax ID to be confirmed), is an obliged entity under Law 10/2010 and applies the customer due diligence, internal control and reporting measures set out in that law.

2. Customer due diligence (KYC)

Before establishing the business relationship we apply customer due diligence measures to every customer:

  • Formal identification and verification of the customer's identity and, where applicable, the beneficial owner.
  • Obtaining information on the intended purpose and nature of the business relationship.
  • Ongoing monitoring of the business relationship to ensure that transactions are consistent with our knowledge of the customer.

3. Use of the address conditional on KYC approval

The professional business address may not be used as, or shown as, your company's address until the identity verification (KYC) has been completed and approved. We reserve the right to request additional information or documentation at any time.

4. Customer obligations

  • Provide truthful, accurate and up-to-date information and documentation.
  • Report without delay any change in the information provided, including in relation to the beneficial owner.
  • Cooperate with due diligence measures and ongoing monitoring.

5. Record-keeping

We keep the documentation and records arising from due diligence measures for the period required by law, generally ten years, with the confidentiality and security safeguards provided for in the legislation.

6. Reporting of suspicious activity

Where there are indications or certainty that certain transactions may be linked to money laundering or terrorist financing, we are obliged to report this to SEPBLAC (the Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offences). The law prohibits us from informing the customer or third parties that such a report has been made.

7. Refusal and termination for non-compliance

If due diligence measures cannot be completed, or if the customer fails to provide the required information, we will not establish the business relationship or we will terminate it, without prejudice to any reports legally required.

Contact

For any question about our KYC and compliance procedures, you can contact us at:

info@sotoworks.es

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