1. Company overview
This Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Policy applies to RomConsult.
RomConsult provides professional consulting services in digital marketing, cloud infrastructure, and business technology. We are a low-risk, non-custodial service provider. We do not hold, transfer, or process funds on behalf of third parties. Payments received are solely for services rendered directly to clients.
2. Risk profile
RomConsult maintains a low-risk profile for money laundering and terrorist financing due to the following factors:
- We provide professional consulting services and do not offer financial services.
- We do not hold client funds or act as an intermediary for payments.
- Transactions are direct payments for services rendered.
- Payments are processed through regulated third-party payment processors (Stripe, PayPal, Square).
- Our client base consists primarily of businesses and professionals in established markets.
3. Client verification procedures
Before establishing a business relationship, we verify client legitimacy through:
- Collection of client name, email address, and contact information.
- Verification of email address through confirmation.
- For business clients, collection of company name and business details.
- Review of payment method to ensure it originates from a legitimate, regulated source.
- Rejection of clients who refuse to provide basic identification information.
Enhanced verification may be conducted for high-value transactions or when risk indicators are present.
4. Transaction monitoring
We monitor transactions for suspicious activity, including:
- Unusually large or frequent purchases inconsistent with a client's stated needs.
- Requests to split transactions without a legitimate business reason.
- Payments from jurisdictions unrelated to a client's stated location.
- Attempts to use multiple payment methods for a single transaction.
- Clients who are evasive about identity or business purpose.
Suspicious activity is escalated internally for review and, where required by law, reported to the appropriate authorities.
5. Sanctions screening
We do not provide services to individuals, entities, or residents of countries subject to comprehensive sanctions. We screen against:
- UK HM Treasury Sanctions List.
- US OFAC Specially Designated Nationals (SDN) List.
- EU Consolidated Sanctions List.
We do not provide services to clients located in or associated with sanctioned jurisdictions including, but not limited to, North Korea, Iran, Syria, Cuba, and the Crimea, Donetsk, and Luhansk regions.
6. Record keeping
We maintain records of business transactions in compliance with applicable laws:
- Client identification records are retained for 5 years after the business relationship ends.
- Transaction records (invoices, receipts, payment confirmations) are retained for 7 years.
- Service-related communication records are retained for 5 years.
Records are stored securely and made available to competent authorities upon lawful request.
7. Prohibited activities
RomConsult will not:
- Accept cash payments or cryptocurrency.
- Process payments on behalf of third parties.
- Provide services to clients on sanctions lists.
- Engage in transactions with no clear business purpose.
8. Compliance responsibility
Management is responsible for ensuring adherence to this policy. This policy is reviewed annually and updated as needed to reflect changes in regulations or business operations.
9. Contact information
For compliance inquiries, contact support@rom-consult.com.