AML, CFT & Sanctions Policy
Our Commitment
Royce maintains a risk-based financial-crime compliance programme designed to prevent its products, Accounts and payment channels from being used for money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud or other unlawful activity.
Policy scope
AML, CFT, proliferation financing and targeted financial sanctions.
Contents
- 1Purpose and status
- 2Applicable Royce entity
- 3Regulatory framework
- 4Risk-based approach
- 5Client identification and verification
- 6Beneficial ownership and authority
- 7Enhanced due diligence
- 8Sanctions and screening
- 9Source of funds and source of wealth
- 10Funding and withdrawal controls
- 11Ongoing monitoring and information updates
- 12Suspicious activity and regulatory reporting
- 13Record keeping and cooperation
- 14Use of service providers and reliance
- 15Restrictions, refusal and termination
- 16Client responsibilities
- 17Policy administration and contact
- 18Definitions
1.Purpose and status
1.1This public Policy describes the principal controls applied by Royce to identify, assess and manage risks relating to money laundering, terrorist financing, proliferation financing, targeted financial sanctions and associated financial crime.
1.2The Policy is a summary of Royce’s external approach. It does not disclose confidential monitoring scenarios, risk scores, escalation thresholds, reporting criteria or investigative methods. Those matters are governed by internal policies, procedures and Applicable Law.
1.3This Policy forms part of the information made available to Clients and prospective Clients. It does not limit any right, obligation or discretion contained in the applicable Client Agreement or imposed by Applicable Law.
2.Applicable Royce entity
| Contracting entity | Regulatory status | Application |
|---|
| Royce Global Markets Limited |
Financial Services Commission, Mauritius; Investment Dealer (Full Service Dealer, excluding Underwriting); licence GB25205368 |
Mauritius legal and regulatory requirements and applicable international sanctions obligations |
| Royce Capitals Ltd. |
Labuan Financial Services Authority; Labuan Money-Broking Business; licence MB/23/0113 |
Malaysian and Labuan legal and regulatory requirements and applicable international sanctions obligations |
2.1The Client’s contracting entity is identified in the Client Agreement, Account documentation or Trading Platform. Each Royce entity applies this Policy subject to the laws, regulatory requirements and directions applicable to it.
2.2Where a requirement differs between jurisdictions, the applicable Royce entity will follow the requirement governing that entity and may apply a higher group standard where lawful and appropriate.
3.Regulatory framework
3.1Royce Global Markets Limited operates within the Mauritius framework, including the Financial Intelligence and Anti-Money Laundering Act, the Financial Intelligence and Anti-Money Laundering Regulations 2018, applicable targeted-financial-sanctions legislation, and FSC rules, codes, guidance and the AML/CFT Handbook, in each case as amended or replaced.
3.2Royce Capitals Ltd. operates within the Malaysian and Labuan framework, including the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 and applicable Labuan FSA requirements, directives and guidance, in each case as amended or replaced.
3.3Royce also has regard to applicable United Nations sanctions and relevant international standards, including standards issued by the Financial Action Task Force, to the extent required or appropriate for its regulated activities.
4.Risk-based approach
4.1Royce applies a risk-based approach. The nature and extent of due diligence and monitoring may vary according to factors including the Client, beneficial owner, jurisdiction, occupation or business, ownership structure, product, delivery channel, expected activity, payment method and source of funds or wealth.
4.2A Client may be assessed as presenting lower, standard or higher risk. Classification is confidential, may change over time and does not create a right to any particular level of due diligence or service.
5.Client identification and verification
5.1Before establishing or continuing a business relationship, Royce may obtain and verify information necessary to understand the identity, legal capacity, ownership, control, purpose and intended nature of the relationship.
5.2For an individual, information may include full legal name, date and place of birth, nationality, residential address, tax residence, occupation, employer or business, contact details, identification documents, biometric or liveness checks and other verification evidence.
5.3For a legal person or arrangement, information may include constitutional and registration documents, registered and operating addresses, nature of business, ownership and control structure, directors, partners, trustees, authorised persons and ultimate beneficial owners.
5.4Royce may verify information through documents, electronic identity-verification services, registries, databases, screening providers, open-source information or direct enquiries. Certification, translation, notarisation or additional evidence may be required.
6.Beneficial ownership and authority
6.1Royce takes reasonable measures to identify and verify the natural person or persons who ultimately own or control a Client, or on whose behalf a relationship or transaction is conducted, in accordance with Applicable Law.
6.2A person acting for a Client must be properly authorised and may be subject to identification, verification, sanctions, PEP and adverse-information screening.
6.3Nominee, trust, foundation, partnership, layered or otherwise complex structures may require additional information concerning their purpose, controllers, settlors, trustees, protectors, beneficiaries, partners or equivalent persons.
7.Enhanced due diligence
7.1Royce may apply enhanced due diligence where higher risk is identified or Applicable Law requires it. This may include obtaining additional identity, ownership, source-of-funds, source-of-wealth, business, tax, financial or transactional information; independent corroboration; senior approval; and enhanced monitoring.
7.2Higher-risk factors may include political exposure, high-risk or sanctioned jurisdictions, unusual or complex ownership, non-face-to-face risk, adverse information, activity inconsistent with the Client profile, unusual payment arrangements or other financial-crime concerns.
7.3A politically exposed person, and where applicable a family member or close associate, is not automatically prohibited. The relationship is subject to the enhanced measures and approvals required by Applicable Law and Royce’s risk assessment.
8.Sanctions and screening
8.1Royce screens Clients, beneficial owners, controllers, authorised persons and, where appropriate, counterparties and transactions against applicable sanctions, terrorism, proliferation-financing, PEP and adverse-information sources.
8.2Royce will not knowingly make funds, financial services or economic resources available where prohibited. It may reject, suspend, freeze, block, restrict or report a relationship, payment or transaction where required by Applicable Law or a competent authority.
8.3Screening is ongoing and may produce false or incomplete matches. Royce may request information before resolving a match and may be legally restricted from explaining a delay, restriction, report or investigation.
9.Source of funds and source of wealth
9.1Royce may request evidence establishing how particular funds were acquired and, where appropriate, how the Client’s overall wealth was generated. The scope of evidence depends on the risk and circumstances.
9.2Evidence may include bank or payment statements, payslips, tax records, audited accounts, contracts, sale or inheritance documents, investment records, corporate ownership information or other reliable evidence.
9.3Royce may decline, delay or return funds where their origin, ownership, purpose or economic rationale cannot be satisfactorily established.
10.Funding and withdrawal controls
10.1Royce does not accept physical cash. Funding and withdrawals must use payment methods approved for the relevant Account, entity, jurisdiction and Client.
10.2Payments should ordinarily originate from and be returned to a verified account or payment method held in the Client’s own name. Third-party payments are not accepted unless expressly approved following appropriate due diligence and where permitted by Applicable Law.
10.3Royce may request proof of ownership of a bank account, card, wallet or payment instrument. It may restrict the destination, sequence or method of a withdrawal to support verification, fraud prevention, sanctions compliance, payment-provider requirements or return-to-source controls.
10.4Royce may reject anonymous, fictitious, unverified, structured, circular or otherwise suspicious funding arrangements and may impose reasonable funding or withdrawal controls consistent with the Client Agreement and Applicable Law.
11.Ongoing monitoring and information updates
11.1Royce monitors the business relationship on a continuing and risk-sensitive basis. Monitoring may consider Account funding, withdrawals, trading behaviour, ownership, access, device and location indicators, payment activity, counterparties and consistency with the known Client profile.
11.2Royce may periodically refresh Client information and may request updated documents or explanations at any time. A Client must promptly notify Royce of changes to identity, address, tax residence, ownership, control, authority, occupation, business, source of funds or other material information.
11.3A request for updated information does not imply wrongdoing. Failure to provide satisfactory information within the period specified by Royce may result in restrictions or termination.
12.Suspicious activity and regulatory reporting
12.1Where Royce knows, suspects or has reasonable grounds to suspect unlawful activity, it may make a report to the relevant financial intelligence unit, regulator, law-enforcement body or other competent authority and may provide supporting information as permitted or required by law.
12.2Royce may delay, reject, restrict or refrain from executing an instruction where necessary to comply with Applicable Law, a lawful direction or its financial-crime controls.
12.3Royce may be prohibited from informing a Client that a report has been made, that information has been requested by an authority or that an investigation or review is being conducted. Nothing in this Policy requires Royce to make a disclosure prohibited by law.
13.Record keeping and cooperation
13.1Royce retains identification, verification, Account, communication, payment, transaction, risk-assessment and investigation records for at least the period required by Applicable Law. Records may be retained longer where required for legal, regulatory, investigative or dispute purposes.
13.2Royce may cooperate with regulators, financial intelligence units, law-enforcement agencies, courts, payment institutions, banks, liquidity providers and other competent or regulated parties where disclosure is lawful and appropriate.
13.3Personal data is processed in accordance with the applicable Royce Privacy Policy and Applicable Law. Financial-crime compliance may require processing without consent where another lawful basis applies.
14.Use of service providers and reliance
14.1Royce may use regulated or specialist service providers for identity verification, screening, fraud prevention, transaction monitoring, document authentication, data validation, payment processing and record storage.
14.2Where Royce relies on or outsources a function, responsibility remains allocated in accordance with Applicable Law. Royce may independently request information even where another regulated person has performed due diligence.
15.Restrictions, refusal and termination
15.1Royce may refuse to onboard a person, reject funds, limit products or payment methods, suspend or place an Account in close-only mode, withhold processing pending review, return funds, close Positions where permitted, or terminate the relationship where due diligence cannot be completed or financial-crime risk is unacceptable.
15.2Royce may act immediately where required by sanctions, a competent authority, fraud or security concerns, suspected unlawful activity or other material risk. Otherwise, any notice and closure process will be governed by the Client Agreement and Applicable Law.
15.3Royce is not required to establish a relationship or process a transaction merely because documents have been submitted, identity has been verified or funds have previously been accepted.
16.Client responsibilities
16.1The Client must provide complete, accurate, current and non-misleading information; respond promptly to reasonable requests; act only for lawful purposes; use payment methods the Client is authorised to use; and not conceal another person’s ownership, control or involvement.
16.2The Client must not use an Account to receive, hold, transfer, layer, disguise or return funds for another person; evade sanctions or reporting obligations; misrepresent payment ownership; or facilitate fraud, tax crime, corruption, market abuse or other unlawful activity.
16.3The Client remains responsible for compliance with laws applicable to the Client, including tax, exchange-control, sanctions and reporting obligations. Royce does not provide legal or tax advice through this Policy.
17.Policy administration and contact
17.1This Policy is Version 1.0 and is effective from 19 August 2026. Royce may amend it to reflect changes in law, regulation, risk, products, systems or operational arrangements. The current version published through an approved Royce channel prevails.
17.2Questions concerning this Policy may be submitted to support@roycecapitals.com or through another approved Royce contact channel. Royce will not discuss confidential monitoring rules, reports or investigations.
17.3Complaints are handled under the complaints procedure of the applicable Royce contracting entity. Governing-law and jurisdiction provisions are set out in the applicable Client Agreement.
