Compliance and Regulatory Disclosure
1. Introduction
Plutus Holding AG (“Plutus”), a Swiss-based financial holding company, is committed to conducting its business in strict adherence to all applicable anti-money laundering (AML) and counter-terrorism financing (CTF) regulations. These include, but are not limited to, the Swiss Anti-Money Laundering Act (AMLA), the Anti-Money Laundering Ordinance (AMLO), the Financial Market Supervision Act (FINMASA), and the relevant directives issued by the Swiss Financial Market Supervisory Authority (FINMA). This policy outlines the core principles and internal procedures established by Plutus to ensure effective risk prevention across its subsidiaries, covering activities such as portfolio management, crypto brokerage, and tokenization.
2. Regulatory Framework
Plutus operates within a rigorous regulatory framework that reflects both national and international standards. We ensure full compliance with AMLA, AMLO-FINMA, the Financial Services Act (FinSA), the Financial Institutions Act (FinIA), and the applicable recommendations of the Financial Action Task Force (FATF). Where applicable, Plutus maintains affiliation with a recognized Swiss self-regulatory organization (SRO) in accordance with Article 24 AMLA, further reinforcing our commitment to upholding the integrity of the financial system.
3. Risk-Based Approach
To effectively prevent financial crime, Plutus adopts a risk-based approach to client and transaction evaluation. Each client relationship and financial transaction is assessed to determine its level of risk with respect to money laundering or terrorism financing. This evaluation considers several factors, including the client’s jurisdiction, legal form, the complexity and nature of the services requested, and the origin of the funds involved. Higher-risk clients or situations trigger enhanced due diligence measures to mitigate potential vulnerabilities.
4. Customer Due Diligence (CDD) and KYC Obligations
Prior to establishing any business relationship, Plutus performs thorough customer due diligence to verify the identity of clients and the beneficial owners of legal entities. This process includes collecting official identification documents, verifying corporate structures, understanding the source of wealth and the origin of funds, and establishing the intended nature and purpose of the relationship. These procedures are not one-time verifications but continue throughout the business relationship. Regular reviews ensure that client profiles remain current and that activities are consistent with the client’s stated financial behavior. For corporate entities, we obtain and validate commercial register extracts, statutes, and identification of controlling individuals.
5. Enhanced Due Diligence (EDD)
In circumstances where a client or transaction presents an elevated risk—such as dealings involving politically exposed persons (PEPs), clients domiciled in high-risk jurisdictions, or unusually complex financial arrangements—Plutus applies enhanced due diligence. This involves more stringent identity verification, additional documentary evidence, close transaction scrutiny, and mandatory approval by senior compliance staff before the relationship can proceed. Monitoring of these clients remains particularly intensive and continuous.
6. Transaction Monitoring and Ongoing Surveillance
All transactions are continuously monitored using both automated systems and manual review processes. This ensures that transactions align with the client’s profile and declared economic activity. Irregular, unusually large, or complex transactions without a clear economic or lawful purpose are subject to further investigation. If suspicions persist, the matter is escalated to our Compliance Department, which determines whether the activity must be reported to the Swiss Money Laundering Reporting Office (MROS).
6. Transaction Monitoring and Ongoing Surveillance
All transactions are continuously monitored using both automated systems and manual review processes. This ensures that transactions align with the client’s profile and declared economic activity. Irregular, unusually large, or complex transactions without a clear economic or lawful purpose are subject to further investigation. If suspicions persist, the matter is escalated to our Compliance Department, which determines whether the activity must be reported to the Swiss Money Laundering Reporting Office (MROS).
7. Record Keeping
In accordance with AMLA and regulatory obligations, Plutus maintains complete and accurate records of all KYC documentation, client risk profiles, transaction histories, and compliance reviews. These records are retained for a minimum of ten years following the end of a client relationship or completion of a transaction, in order to satisfy audit and legal requirements.
8. Internal Controls and Staff Training
Plutus maintains a robust internal control system and a comprehensive AML compliance framework. This includes regularly updated internal policies and a structured training program for all employees. Staff members—particularly those in compliance, onboarding, operations, and front-office roles—are trained to recognize signs of suspicious behavior, understand legal requirements, and know how to escalate concerns appropriately. Training sessions are documented and reviewed to reflect changes in regulatory expectations.
9. Compliance Function and Governance
Oversight of AML and KYC implementation falls under the responsibility of the appointed Compliance Officer, who ensures adherence to both internal procedures and external legal obligations. This individual serves as the primary liaison with regulatory bodies, monitors internal compliance systems, and leads investigations into suspicious activity. At the governance level, the Audit & Risk Committee of the Board supervises the implementation and effectiveness of the AML program.
10. Cooperation with Authorities
Plutus fully cooperates with Swiss regulatory and law enforcement authorities and complies with all legal obligations to report suspicious activity. We do not tolerate any use of our platform for the purposes of money laundering, terrorism financing, or attempts to circumvent international sanctions. Our policy is to act decisively and transparently when faced with such risks.
11. Sanctions Screening and PEP Identification
Plutus uses advanced screening tools to identify individuals or entities subject to international sanctions, asset freezes, or restrictions. We also identify and appropriately classify politically exposed persons. Where a match or hit occurs, our Compliance Department reviews and evaluates the risk. Appropriate measures—including denial of service or reporting to MROS—are taken as required.
12. Policy Review and Updates
This AML & KYC Policy is reviewed on a regular basis, at least annually, and updated in response to any significant regulatory, legal, or operational changes. All revisions are approved by senior management and submitted to the Board of Directors for oversight.
Last updated: 28.06.2025