AML and international sanctions

Version 19 October 2026

Declaration for direct VERDT small purchases

For direct purchases of the issuer’s own VERDT, the Buyer confirms the lawful source of funds and that the purchase is made in the Buyer’s own name and for the Buyer’s own account. A representative confirms authority to act for the Buyer identified in the agreement. The declaration forms part of the order and purchase agreement. Its exact wording and the agreement acceptance record are retained. It is a contractual preventive measure. Payment providers or banks may apply their own identification requirements.

Purpose of AML and sanctions measures

The measures aim to prevent money laundering, terrorist financing and breaches of international sanctions. Legal duties depend on the specific entity, activity, transaction and jurisdiction. This overview is not a confirmation of LTD licensing or regulated status.

Customer and representative identification

Before a relationship or transaction, the relevant obliged entity may require identification of individuals or entities, verification of authority to act and identification of the beneficial owner. Verification must comply with applicable law. An ordinary email, contact form or purchase enquiry does not replace identification.

Due diligence and source of funds

Depending on risk, checks cover the purpose and nature of the relationship, source of funds, beneficial ownership and potential political exposure. Supporting documents may be requested. Monitoring may continue throughout the business relationship. Applicable sanctions lists and risk factors are also checked.

Failure to meet requirements and statutory procedures

A transaction or relationship may not proceed if required checks or legal conditions cannot be met. Any suspicious transaction reporting follows applicable law and confidentiality duties. This website does not provide guidance for circumventing controls.

Secure document submission

Do not send identity documents or source-of-funds evidence through the ordinary contact form. First contact the relevant staff member and request the approved submission method. Documents are processed only to the necessary extent and retained for the period prescribed by applicable law.

Existing LTD internal policy

Documents retains the complete original LTD policy No. 1/2025 effective from 1 July 2025, including its annexes. The original policy contains internal procedures and legal references reflecting the model at that time. Its revision for VERDT and the allocation of responsibilities between LTD, the fund and APF Malta require separate approval. This bilingual overview does not replace it.