Legal Documents
[I] Prohibitions
Bilderlings has no appetite for customers or contractors, who engage in any of the following:
- Intentional or willfully negligent breaches of law, regulation or policy concerning Financial Crime;
- Repeated unintentional or repeated accidental breaches of law, regulation or policy concerning Financial Crime;
- Misusing Bilderlings products and services for the purpose of Financial Crime;
- Facilitating business activities, which could be interpreted as a tax offence; and
- Refusing or avoiding to provide sufficient information or documentation to demonstrate compliance.
Bilderlings is aiming to conduct business only with reputable customers or vendors and whose identities can be reliably determined and verified.
Bilderlings reserves the right to terminate relationships with any customer or vendors, refuse payment, or business that is not compliant with Bilderlings’ risk appetite.
Bilderlings will not knowingly enter into a business relationship with persons that seek to process payments involving:
- Illegal Gambling entities;
- Weapon dealers/intermediaries/purchasers*;
- Illegal drugs or precursors;
- Anonymous accounts or customers seeking to maintain an account in an obviously fictitious name;
- Human Trafficking or Modern Slavery;
- Shell Banks, i.e. banks with no physical presence or staff, or financial institutions which cooperates with shell banks;
- Adult-online live content, webcam, online streaming content and acts of offensive adult content, Adult advertising, Child Pornography, Bestiality;
- Rape/Hate/Violence;
- Replica/Copyright infringement;
- Companies which issue bearer shares**;
- Unlicensed financial institutions;
- Privacy coins e.g. Monero, Zcash and Dash;
- Ponzi / pyramid schemes;
- Binary Options; and
- ICO incl. subscriptions, placement or distribution.
* Weapons of war, automatic weapons, ammunition or defence equipment, chemical weapons, cluster bombs, ammunitions, or other defence equipment or similar
** Bearer shares refer to negotiable instruments that accord ownership in a legal person to the person who possesses the physical bearer share certificate, and any other similar instruments without traceability. It does not refer to dematerialised and/or registered forms of share certificate whose owner can be identified.
Bilderlings Risk Appetite with respect to higher risk customers focuses on the establishment of ongoing processes of developing, updating and implementing internal controls, in order to detect, prevent and minimise the risk of Bilderlings being used for Financial Crime. Bilderlings uses appropriate measures and controls to mitigate the potential Financial Crime risk of those customers/transactions that are determined as high risk. These measures include:
- Increased awareness of higher risk situations within business lines through enhanced and specialised training;
- Increased levels of know your customer (“KYC”) and know your customer’s business (“KYCB”) and enhanced due diligence for high risk customers, including PEPs;
- Escalation for approval of the establishment of a new, or the maintenance of an existing, business relationship;
- Quality Assurance of customer’s onboarding by both the AML and Compliance teams;
- Periodic KYC reviews for all customers, which includes a review of all KYC documents obtained during onboarding to ensure they remain up to date as well as ongoing scrutiny of the customer’s transactions;
- Customer and Payment screening for sanctions purposes;
- Combination of automated and manual on-line transaction monitoring;
- Automated transaction monitoring of all transactions post event.
[II] Banned CountriesNb
Bilderlings has no appetite for customers or contractors who are registered, or are citizens or residents, of the following countriesR. Further we should not accept payments from these countries either from the customer directly or via the customer’s business partners:
- Afghanistan;
- Burundic;
- Cambodiac;
- Cameroonc;
- Central African Republic;
- Chadc;
- Cuba****;
- Eritreac;
- Ethiopia;
- North Korea (DPRK);
- Democratic Republic of the Congoc;
- Haitic;
- Iran;
- Iraq;
- Lebanon;
- Libya;
- Malic;
- Mozambiquec;
- Myanmar (Burma)c;
- Nicaraguac;
- Pakistanc;
- Palestine;
- Senegalc;
- Sierra Leone;
- Somalia;
- South Sudan;
- Sudan;
- Syria;
- Ugandac;
- Venezuela;
- Yemen;
- Zimbabwe;
- Government and non-government controlled Ukrainian territory***
- Contested territories that are not internationally recognised:
Transdniestria,
The Crimea Region (Ukraine),
Abkhazia,
South Ossetia etc.**
R Ban on account opening applies on citizens of the banned countries irrelevant to their place of residence
Nb If a new country is added to the Banned Country list, Bilderlings may continue business relations with a client who is a resident or citizen of that country, subject to the relevant decision of the FCC.
** Contested territories that are not internationally recognized refer to regions that have declared independence or autonomy from a recognized state, but their sovereignty is not recognized by the international community.
*** Means areas of the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts; We do not open accounts for clients from these territories; However, the payments from/to Ukrainian governmentally controlled territories of Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts could be made, if it does not breach the sanctions and relevant UK law (manual control is applied).
**** Payments to/from jurisdiction in GBP and EUR may be processed subject to manual review. Transit payments from the U.S. or payments with conversion from/to USD are prohibited. Payments from/to U.S. persons are prohibited.
Cards services related limitations
Bilderlings Cards are not operating in Ethiopia, Russia and Banned Countries (except for those Banned Countries marked as “c” ). Operations of the Cards in Belarus are limited.
[III] Sanctions Risk Appetite
Bilderlings has no appetite for customers who are:
- legal entities established in Russia or Belarus, or legal entities in which natural persons residing in Russia or Belarus, individually or collectively, have more than 25% of shares or voting rights;
- natural persons residing in Russia or Belarus;
Bilderlings is committed to complying with the sanction’s laws and regulations:
- Screening customers/clients and transactions globally against the sanctions lists issued by the United Kingdom’s HM Treasury (HMT), the European Union, the United Nations, and the United States of America Department of the Treasury – Office of Foreign Assets Control (OFAC);
- Prohibiting business activity, including prohibitions on commencing or continuing customer relationships or providing products or services or facilitating transactions that Bilderlings believes may violate applicable sanctions laws or Bilderlings Policies. This includes individuals or entities named on a sanctions list or activity, directly or indirectly, involving countries or territories subject to comprehensive sanctions;
- Restricting business activity involving, directly or indirectly, countries or persons subject to more selective or targeted sanctions programmes. These restrictions impact not only the types of products or services that Bilderlings may make available but also the types of transactions Bilderlings may process;
- Investigating all customer/client alerts or transactions that are flagged in Bilderlings screening systems. Whilst Bilderlings seeks to investigate these alerts and transactions in a reasonable timeframe, compliance with applicable sanctions laws or Bilderlings Policies may result in delays to the processing of customer transactions while additional due diligence is conducted, and information obtained on the nature of the underlying transaction or the parties involved;
- Reporting breaches of sanctions laws to the relevant regulatory authority. This may include any attempt by a customer to evade sanctions laws; and
- All relevant employees receive ongoing training on the Sanctions and Compliance updates.
Approved on 30/06/2025 Board meeting (AML-STA-001)
