1. Statement of commitment
Calculativa Systems Limited is committed to preventing its services from being used to launder the proceeds of crime, to finance terrorism, or to evade sanctions. We apply a risk-based approach in line with the EU anti-money-laundering framework as transposed in Malta, and with the recommendations of the Financial Action Task Force.
This is a summary of our public position. Our full internal control framework, business risk assessment and procedures manual are confidential documents made available to auditors, counterparties and competent authorities on a legitimate need-to-know basis.
2. Why this policy exists
Providers of accountancy and bookkeeping services are subject persons under applicable anti-money-laundering legislation. Because we maintain clients’ accounting records, prepare their financial statements and assist with statutory filings, we are required to identify our clients, understand their business and report suspicion. This policy sets out how we do that.
We do not handle client money. Calculativa Systems Limited is not a payment institution, electronic money institution, payment processor or money services business. We do not hold, receive, transmit or take title to client or third-party funds, and we do not provide merchant acquiring or virtual-asset services. Where a client authorises us to read bank or system data, that access is used solely to maintain and reconcile the client’s own accounting records.
3. Scope
This policy applies to all directors, employees, contractors and third-party agents of Calculativa Systems Limited, and to every client relationship we enter into.
4. Client due diligence
We do not begin work before client due diligence is complete. Depending on the assessed risk, we will request:
4.1 Corporate clients
- Certificate of incorporation and current registry extract
- Memorandum and articles of association
- Register of directors and register of shareholders
- Identification of all ultimate beneficial owners holding, directly or indirectly, more than 25% of shares or voting rights
- Identity documents and proof of address for directors, authorised signatories and beneficial owners
- Evidence of the nature of the business, its source of funds and the purpose of the engagement
- Group structure chart where the client forms part of a group
4.2 Enhanced due diligence
Enhanced measures — including senior-management approval, additional source-of-wealth evidence and closer ongoing scrutiny — are applied where a relationship presents higher risk, including where it involves a politically exposed person, a high-risk third country, a complex or unusually opaque ownership structure, or a sector we assess as elevated risk.
5. Screening
Clients, beneficial owners and directors are screened at onboarding and on an ongoing basis against consolidated sanctions lists (including those maintained by the European Union and the United Nations Security Council), politically exposed person registers and adverse-media sources. Positive matches are escalated for review before any relationship proceeds.
6. Ongoing monitoring of the relationship
Client relationships are monitored throughout their life. The activity we observe in the accounting records we maintain is assessed against the business profile established at onboarding. Material inconsistencies — entries without adequate supporting documentation, arrangements with no apparent commercial rationale, or patterns inconsistent with the client’s stated business — generate an internal case for investigation. Client due-diligence records are refreshed periodically on a frequency determined by the assessed risk rating.
7. Relationships we will not accept
We will not establish or maintain a client relationship where:
- the client refuses or fails to provide required due-diligence information;
- the identity of a beneficial owner cannot be established to our satisfaction;
- the client, a beneficial owner or a controller is subject to applicable financial sanctions;
- the ownership structure appears designed principally to obscure control or ultimate ownership;
- we have reasonable grounds to suspect the relationship involves the proceeds of criminal activity or the financing of terrorism.
8. Reporting
Suspicious activity is reported internally to the officer responsible for anti-money-laundering compliance and, where the applicable threshold is met, externally to the competent Financial Intelligence Unit. Our personnel are prohibited from disclosing to a client or any third party that a report has been made or is contemplated, in accordance with statutory tipping-off provisions.
9. Record keeping
Client due-diligence records, engagement records and internal investigation files are retained for the period prescribed by applicable law — generally five years from the end of the client relationship — and are held securely under access control for the whole of that period.
10. Governance and training
Responsibility for this framework rests with the board, which appoints an officer accountable for anti-money-laundering compliance. All personnel receive anti-money-laundering and sanctions training on joining and periodically thereafter, covering recognition of suspicious indicators and the internal escalation route. The framework and the underlying business risk assessment are reviewed at least annually and whenever a material change occurs in our services, clients or markets.
11. Cooperation with authorities
We cooperate fully with competent supervisory and law-enforcement authorities and respond to lawful information requests within the timeframes required.
12. Contact
Compliance enquiries, including requests for due-diligence documentation about Calculativa Systems Limited itself, should be addressed to legal@calculativa.com.