1. Purpose
Wentura is committed to preventing money laundering, terrorist financing, sanctions evasion, fraud, corruption, and other unlawful activity. This policy describes the general risk-based approach that may apply to applicants, borrowers, guarantors, beneficial owners, counterparties, wallets, and transactions.
2. Identity and business verification
Wentura may verify legal name, date of birth, address, nationality, incorporation, registration, ownership, control, directors, authorised representatives, business purpose, and expected activity. Documentary and electronic verification may be used.
3. Beneficial ownership and control
Applicants may be required to identify individuals who ultimately own, control, direct, or benefit from an organisation or arrangement. Wentura may also verify wallet signers, governance rights, treasury authority, and connected entities.
4. Source of funds and wealth
Wentura may request information about the origin of assets, revenue, collateral, treasury balances, and repayment funds. Evidence may include transaction history, contracts, invoices, financial statements, bank or custody records, tax records, and explanations of blockchain activity.
5. Sanctions and adverse-information screening
Applicants, owners, representatives, counterparties, addresses, and transactions may be screened against sanctions lists, politically exposed person data, law-enforcement information, adverse media, fraud indicators, and blockchain-risk data.
6. Ongoing monitoring
Wentura may monitor changes in ownership, control, wallets, transaction patterns, counterparties, jurisdiction, business activity, sanctions exposure, source of funds, and other risk factors throughout a relationship.
7. Records and disclosure
Records may be retained as required for compliance, audit, disputes, and legal duties. Wentura may make reports or disclose information to competent authorities where required or permitted by law. We may be prohibited from informing a person about certain reports or investigations.
8. Refusal, delay, or termination
Wentura may request additional information, delay a transaction, restrict activity, decline an application, freeze an internal process, or terminate a relationship where permitted by law and required by risk, policy, sanctions, or legal obligations.
9. Applicant responsibilities
Applicants must provide accurate information, disclose relevant ownership and control, explain funds and transactions, notify Wentura of material changes, and cooperate with lawful checks. Providing false or misleading information may lead to rejection, termination, reporting, or legal action.
10. Questions
General compliance questions may be submitted through the contact form. Do not send identity documents unless Wentura provides a secure method and asks for them.