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AML/KYC POLICY

Last Updated: July, 2025

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PRIME DESK S.R.L. adheres to the laws and regulatory expectations of Costa Rica concerning Anti-Money Laundering (AML) and Know Your Customer (KYC) practices. The company is committed to maintaining a secure and transparent environment that helps prevent the misuse of its services for money laundering, terrorist financing, fraud, or other illicit activities.

 

1. Commitment to Compliance

PRIME DESK S.R.L. ensures that all internal procedures and operational controls align with applicable Costa Rican regulations relating to AML and KYC. This includes the identification, assessment, and ongoing monitoring of clients, as well as cooperation with relevant authorities whenever necessary.

 

2. CUSTOMER IDENTIFICATION PROGRAM (CIP)

Before initiating any business relationship, PRIME DESK S.R.L. carries out a thorough customer identification process.

 

a. Identification Requirements

Information collected includes:

 

  • Full legal name

  • Date of birth (for individuals)

  • Residential or business address

  • Valid government-issued photo identification

  • For legal entities: documentation confirming the company’s legal existence and identity of its legal representatives

  • Clients are required to keep this information accurate and up to date.

 

b. Verification Process

Client information is verified using appropriate tools and procedures. We may engage external verification services to validate identification documents and screen clients against international watchlists or sanctions databases.

 

If any discrepancies or red flags are identified, PRIME DESK S.R.L. will request clarification or additional information before continuing the relationship.

 

c. Incomplete or Misleading Information

In cases where the information provided is misleading, inaccurate, or cannot be verified, the company may suspend or reject the relationship, pending further investigation.

 

d. Enhanced Due Diligence (EDD)

Additional scrutiny is applied to clients or activities considered higher risk. This may include verifying the origin of funds, requesting detailed financial records, or placing accounts under increased transaction monitoring.

 

EDD is also applied where there is a higher potential for reputational or regulatory risk.

 

3. RECORDKEEPING

PRIME DESK S.R.L. maintains secure and confidential records of all identification and verification processes. These records are preserved for the required period after the end of the client relationship and are made available to authorities when requested.

 

All data is handled with strict confidentiality and is stored in secure environments that comply with international data protection standards.

 

4. AML COMPLIANCE OFFICER

A designated Compliance Officer is responsible for the day-to-day oversight of AML and KYC compliance. This includes:

 

  1. Supervising internal controls and verification procedures

  2. Investigating unusual activity

  3. Coordinating internal reporting and staff training

  4. Liaising with authorities if suspicious activity is detected

 

All concerns regarding compliance should be directed to the Compliance Officer.

 

5. TRANSACTION MONITORING

The company monitors client activity to detect patterns that may indicate suspicious or unauthorized transactions. This includes:

 

  1. Establishing client transaction profiles

  2. Real-time monitoring of cryptocurrency transfers

  3. Flagging and escalating out-of-pattern behavior

  4. High-risk accounts are monitored with enhanced scrutiny.

 

6. RISK MANAGEMENT

PRIME DESK S.R.L. applies a risk-based approach to all clients and services. Risk levels are determined during onboarding and adjusted through periodic reviews. The compliance team regularly evaluates procedures and performs internal audits to ensure effectiveness.

 

To maintain high standards, staff are regularly trained in the latest methods of customer due diligence and financial crime prevention.

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