ANTI-MONEY LAUNDERING POLICY

ELPASO is committed to upholding the highest standards of integrity and probity in the conduct of its affairs with its clients, counterparties, and regulators. As a part of our internal AML Policy, ELAPSO, having assessed relevant risks, will not conduct any business (will not open an account and will not support transactions) with (potential) clients, third parties and their counterparties or affiliates that have direct or indirect links to the following “Prohibited countries and regions” or “Prohibited industries”. On top of these lists:

  1. ELPASO does not provide any services to the parties whose identity has not been properly verified. All (potential) customers undergo robust due diligence (CDD) before opening an account, as well as periodically after.
  2. ELPASO is not willing to provide services to non-identified third parties, “hiding” behind or “being represented by” the client. If such transactions will be flagged by ELPASO monitoring systems, ELPASO will terminate the relationship with such a client and will report these transactions to authorities as regulation requires.

PROHIBITED COUNTRIES and regions:

  • Afghanistan
  • American Samoa
  • Burundi
  • Cayman Islands
  • Central African Republic
  • Crimea
  • Cuba
  • Democratic Republic of Congo
  • North Korea or Democratic People’s Republic of Korea (DPRK)
  • Fiji
  • Guam
  • Guinea (Republic of Guinea)
  • Guinea-Bissau (Republic of Guinea-Bissau)
  • Iraq
  • Iran
  • Laos
  • Lebanon
  • Libya
  • Mozambique
  • Mali
  • Myanmar
  • Nicaragua
  • Oman
  • Palestinian Territory
  • Palau
  • Pakistan
  • Panama
  • Samoa
  • Seychelles
  • Somalia
  • South Sudan
  • Sudan
  • Syrian Arab Republic (Syria)
  • Tunisia
  • Trinidad and Tobago
  • Vanuatu
  • Virgin Islands (United States)
  • Yemen
  • Venezuela
  • Zimbabwe

Countries that are not listed as PROHIBITED may also have certain limitations, due to:

  • Restrictions from ELPASO banking partners and core service providers;
  • Case by case circumstances.

PROHIBITED INDUSTRIES:

Activities that are directly illegal by law of relevant jurisdictions;

Manufacture maintenance and any type of trade of explosives, weapons, ammunition, and any military-related products and services;

Activities of religious organizations;

Activities of political organizations;

Activities of other membership organizations;

Activities of non-licensed gambling, shell banks, pyramid schemes and other financial service providers that seemingly legally or illegally avoid licensing, authorization and audit;

Industries that are not listed as PROHIBITED may also have certain limitations, due to:

  • Restrictions from ELPASO banking partners and core service providers;
  • Case by case circumstances.

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