Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy
1. Introduction
Plutus Holding AG (“Plutus”) is a Swiss-based financial holding company committed to maintaining the highest standards of integrity and compliance in all aspects of its operations. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy reflects our dedication to ensuring that all activities conducted across our financial ecosystem—ranging from portfolio management to crypto brokerage and tokenization—are fully aligned with the applicable legal framework in Switzerland, notably the Anti-Money Laundering Act (AMLA), the Anti-Money Laundering Ordinance (AMLO), and directives from the Swiss Financial Market Supervisory Authority (FINMA). Where relevant, we also consider international best practices and recommendations issued by the Financial Action Task Force (FATF).
2. Legal and Regulatory Framework
The AMLA and AMLO impose strict obligations on financial intermediaries operating in Switzerland. As a regulated group, Plutus ensures compliance with these laws through robust internal systems designed to prevent money laundering and terrorism financing. We also adhere to related Swiss laws, such as the Financial Institutions Act (FinIA) and the Financial Services Act (FinSA), and maintain affiliation with an authorized self-regulatory organization (SRO) when required. Our internal policies are continually updated to reflect regulatory changes and evolving risks.
3. Client Identification and Due Diligence
Before establishing any business relationship, Plutus conducts thorough due diligence to verify the identity of each client and, where applicable, the beneficial owners of legal entities. This process includes collecting personal and corporate documentation, understanding the origin of funds and the purpose of the relationship, and assessing the client’s risk profile based on factors such as geographic location, legal structure, and transaction behavior. For ongoing relationships, client data is reviewed periodically to ensure consistency with initial disclosures and to identify any anomalies or changes in risk exposure.
4. Risk-Based Approach to Compliance
We adopt a risk-based approach to AML compliance, meaning that the level of scrutiny applied to a client or transaction is proportionate to the level of risk identified. Low-risk clients may undergo simplified due diligence, while high-risk profiles—such as those involving politically exposed persons (PEPs), offshore structures, or jurisdictions subject to sanctions—trigger enhanced due diligence procedures. These additional measures may include collecting more detailed documentation, obtaining approval from senior management, and conducting more frequent reviews.
5. Transaction Monitoring and Suspicious Activity
All client transactions are monitored to ensure they align with the client’s known profile and expected financial behavior. Monitoring is conducted through a combination of automated systems and human oversight, enabling us to promptly detect patterns that may indicate potential money laundering, fraud, or other financial crime. Where suspicious activity is identified, our Compliance team undertakes a formal investigation and, if necessary, files a report with the Swiss Money Laundering Reporting Office (MROS) in accordance with our legal obligations.
6. Record Keeping and Documentation
Plutus retains all documentation related to client onboarding, due diligence, and transaction history for a minimum of ten years after the termination of the business relationship or completion of the transaction. This retention ensures compliance with audit requirements and facilitates future investigations or inquiries by regulatory authorities. Records are stored securely and are accessible only to authorized personnel.
7. Internal Governance and Employee Training
Our AML program is managed by a designated Compliance Officer responsible for developing and enforcing internal policies, providing guidance on high-risk matters, and serving as the point of contact for authorities. Plutus also provides mandatory AML training to all employees, ensuring that staff members are well-equipped to identify suspicious conduct, understand reporting obligations, and uphold the principles of financial integrity. Training is refreshed regularly and adapted to reflect changes in the regulatory environment.
8. Sanctions Screening and Politically Exposed Persons (PEPs)
Plutus employs comprehensive screening tools to identify clients or counterparties that may be subject to international sanctions, asset freezes, or classified as PEPs. This screening is integrated into our onboarding and monitoring processes, and any matches are thoroughly reviewed by Compliance. In such cases, appropriate measures—including declining the business relationship or filing a report—are taken in accordance with legal requirements.
9. Cooperation with Authorities
We maintain open and transparent communication with Swiss regulators and enforcement agencies, and fully cooperate with official investigations or audits. Plutus does not tolerate any attempt to use its services for unlawful purposes and takes decisive action in the event of suspected abuse.
10. Policy Review and Updates
This AML & KYC Policy is reviewed regularly—at least annually—or in response to changes in legislation, regulation, or internal risk assessments. Updates are subject to approval by senior management and, where applicable, the Board of Directors to ensure continued compliance and operational effectiveness.
Last updated: 28.06.2025