Anti-Money Laundering Policy

Last updated: May 1, 2025

Landercrest Wealth Management, LLC is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our obligations and procedures under applicable law.

1. Legal Framework

Our AML programme is designed to comply with the Bank Secrecy Act (BSA), the USA PATRIOT Act, Financial Crimes Enforcement Network (FinCEN) regulations, and all applicable state and federal laws governing financial services.

2. Know Your Customer (KYC)

We are required to verify the identity of all clients before providing services. Our KYC process includes:

Identity verification — government-issued photo ID, proof of address
Source of funds — documentation establishing the legitimate origin of invested capital
Beneficial ownership — identification of all beneficial owners for corporate accounts
Ongoing monitoring — continuous review of account activity and periodic re-verification

3. Prohibited Clients

We will not open or maintain accounts for:

Individuals or entities on OFAC, UN, EU, or other applicable sanctions lists
Politically Exposed Persons (PEPs) without enhanced due diligence approval
Anonymous or pseudonymous clients
Clients from jurisdictions subject to comprehensive sanctions
Shell companies with no identifiable beneficial owner

4. Transaction Monitoring

We monitor all transactions for suspicious activity, including but not limited to:

Unusually large or frequent transactions inconsistent with the client's profile
Structuring transactions to avoid reporting thresholds
Transactions involving high-risk jurisdictions
Rapid movement of funds in and out with no clear investment purpose
Requests to send funds to unrelated third parties

5. Suspicious Activity Reporting

Where we identify or suspect money laundering, terrorist financing, or other financial crime, we are required to file a Suspicious Activity Report (SAR) with FinCEN without tipping off the client. We cooperate fully with law enforcement investigations.

6. Record Keeping

We retain all KYC documentation, transaction records, and SAR filings for a minimum of five (5) years from the date of the transaction or account closure, whichever is later, in compliance with BSA requirements.

7. Staff Training

All Landercrest personnel involved in client onboarding and transaction processing receive regular AML/CTF training. A designated compliance officer oversees our AML programme and ensures it remains current with regulatory developments.

8. Client Obligations

By using our platform, you agree to:

Provide accurate and truthful information during onboarding and on request
Promptly notify us of any changes to your identity, address, or source of funds
Not use our platform for any purpose related to money laundering or terrorist financing

9. Consequences of Non-Compliance

Failure to comply with our KYC/AML requirements may result in account suspension, termination, and reporting to the relevant authorities. We reserve the right to freeze funds pending investigation where suspicious activity is identified.

10. Contact

AML-related enquiries should be directed to our compliance team at compliance@landercrestwealth.com.