CONFIDENTIALITY & ANTI-MONEY LAUNDERING STATEMENT

This Statement sets out the approach of Stone Bridge Capital (MFO) Ltd ("SBC", "we", "us" or "our") to client confidentiality and to the prevention of money laundering, the financing of terrorism and other financial crime. It applies to all client relationships and to all engagements undertaken by us.

SBC is registered in the Republic of Cyprus under registration number HE371697, with registered office at Limassol, Eptanisou 28. We are subject to applicable Cypriot and European Union laws and regulations governing client confidentiality and the prevention of financial crime.

 

1. Our commitment to confidentiality

Client confidentiality is fundamental to our practice. Information relating to our clients, their affairs, their assets, their structures and their transactions is treated as confidential as a matter of course, irrespective of the form in which it is held.

Confidentiality is observed not only with respect to third parties but also internally: client information is restricted to those engaged on the relevant mandate and to trusted third parties (such as lawyers, accountants, auditors and other professional advisers) engaged on a mandate-by-mandate basis with appropriate confidentiality undertakings in place.

We do not publish client names, do not use mandate details for marketing purposes without explicit client consent, and structure our work and communications so that confidential information remains protected throughout and beyond the duration of the engagement.

 

2. Limits of confidentiality

Our confidentiality undertakings are subject to overriding legal and regulatory obligations. We will disclose client information where:

• disclosure is required by applicable law or regulation;

• disclosure is required by an order of a competent court or other authority with jurisdiction;

• disclosure is required in connection with our anti-money laundering and counter-terrorist financing obligations (see Section 4 below);

• the client has given their explicit and informed consent to the disclosure;

• disclosure is reasonably necessary for the protection of our legitimate interests in connection with the engagement (for example, to defend ourselves against a legal claim).

 

3. Information handling and security

We apply administrative, technical and physical safeguards designed to protect confidential client information from unauthorised access, disclosure, alteration or destruction. These safeguards include:

• access controls restricting client information to authorised personnel and engaged third parties on a need-to-know basis;

• use of secure communication channels and encryption where appropriate;

• document retention and destruction in accordance with applicable legal and regulatory requirements;

• contractual confidentiality undertakings with all trusted third parties engaged in connection with client mandates.

 

4. Anti-money laundering compliance

SBC is committed to the prevention of money laundering, the financing of terrorism and other financial crime. We conduct our business in compliance with the applicable Cypriot Anti-Money Laundering legislation and relevant European Union directives, as amended from time to time.

Our anti-money laundering framework includes the following elements.

A. Client due diligence

Before establishing a client relationship, and on an ongoing basis during the relationship, we conduct due diligence procedures to:

• verify the identity of the client (and, where applicable, of the ultimate beneficial owners);

• understand the nature and purpose of the client relationship;

• identify the source of the client’s wealth and the source of funds relevant to the engagement;

• assess the risk profile of the client and the proposed activity.

B. Enhanced due diligence

Where the risk profile of a client or transaction warrants it — including in cases involving politically exposed persons, complex or unusual structures, or higher-risk jurisdictions — we apply enhanced due diligence measures. These typically include obtaining additional documentation, additional verification of source of wealth and source of funds, and senior-level approval before proceeding.

C. Ongoing monitoring

We maintain ongoing monitoring of client relationships and transactions to ensure that they remain consistent with our understanding of the client and their stated activities. We update client due diligence information periodically and whenever circumstances reasonably warrant a review.

D. Sanctions screening

We screen clients and transactions against applicable sanctions lists (including those of the European Union, the United Nations, and relevant national authorities) and decline or terminate engagements that would result in a breach of applicable sanctions.

E. Record keeping

We retain client due diligence records and transaction records for the periods required by applicable law.

F. Reporting obligations

Where we identify activity that gives rise to a suspicion of money laundering or terrorist financing, we report such activity to the competent authorities in accordance with applicable law. Such reporting obligations override our duty of confidentiality where the two are in conflict.

 

5. Client cooperation

Effective compliance with our confidentiality and anti-money laundering obligations depends on cooperation from our clients. We ask our clients to:

• provide accurate and complete information in response to our due diligence requests;

• promptly inform us of material changes in their circumstances, ownership structure or sources of wealth and funds;

• provide supporting documentation where reasonably requested.

We reserve the right to decline or to terminate an engagement where the information required to satisfy our obligations is not provided, or where the client relationship is otherwise not consistent with our risk appetite and compliance framework.

 

6. Changes to this Statement

We may update this Statement from time to time to reflect changes in applicable law, regulatory expectations or our internal practices. When we update it, we will amend the version date at the top of the document.

 

7. Contact

If you have any questions about this Statement, please write to us at:

Stone Bridge Capital (MFO) Ltd

Limassol, Eptanisou 28

Email: solutions@sbc.cy