AML, KYC & sanctions policy

CapitalKey Real Estate & Consulting LLC is committed to preventing money laundering, terrorist financing and sanctions evasion, and works only with legitimate businesses.

Customer due diligence

• Verification of company registration and beneficial owners (25%+).
• Government ID verification of directors and authorized signatories.
• Understanding of the purpose of each engagement.
• Enhanced due diligence for higher-risk clients and politically exposed persons.

Sanctions screening

Clients are screened against OFAC (SDN), EU and UN sanctions lists. We do not work with sanctioned persons or in comprehensively sanctioned jurisdictions.

Scope limits

We provide analysis reports only. We do not act as a real estate broker or agent, do not hold escrow, deposits or purchase funds, and do not take part in property transactions on behalf of clients.

Prohibited activities

We do not accept clients involved in weapons, illegal drugs, gambling, adult content, unlicensed financial services, shell arrangements without economic substance, or cryptocurrency exchange.

Payments

All payments are made by bank transfer from accounts in the client company's name, against invoices for documented services. No cash or third-party payments.

Record keeping

Records are kept for at least five years. Suspicious activity is reported to the competent authorities where required.

Responsibility

This policy is owned by the company's management and reviewed at least annually. Questions: info@capitalkey-consulting.com.