AML policy 

Tonil Trust Limited is committed to maintaining a strong Anti-Money Laundering (AML) framework in compliance with applicable laws and regulations. This policy outlines our commitment to prevent money laundering and the financing of illicit activities within the scope of our operations as a family office and trust.

The objective of our AML Policy is to ensure that Tonil Trust Limited operates with the highest ethical standards, complies with all relevant AML laws, regulations, and guidelines, and actively contributes to the global effort to combat money laundering, terrorist financing, and other illicit activities.

Compliance Responsibilities
2.1 Management Commitment: The management of Tonil Trust Limited is responsible for establishing and maintaining an effective AML framework. They provide oversight, resources, and support to ensure compliance with AML laws and regulations.

2.2 Designated Compliance Officer: Tonil Trust Limited appoints a designated Compliance Officer who is responsible for overseeing and implementing the AML framework. The Compliance Officer acts as a point of contact for all AML-related matters and ensures ongoing monitoring and reporting of suspicious activities.

2.3 Employee Training: All employees are required to undergo regular AML training to understand their responsibilities and stay updated on the latest AML laws, regulations, and best practices. Training sessions are conducted periodically, and records are maintained to demonstrate compliance.

Customer Due Diligence (CDD)
3.1 Identification and Verification: Tonil Trust Limited will perform customer due diligence procedures to identify and verify the identity of clients, beneficial owners, and other relevant individuals/entities as required by applicable laws and regulations.
3.2 Risk-Based Approach: We adopt a risk-based approach to assess the level of due diligence required for each client based on their risk profile. Enhanced due diligence measures are implemented for high-risk clients and transactions.

3.3 Ongoing Monitoring: We maintain an ongoing monitoring process to identify and report any suspicious activities. This includes reviewing and updating client information periodically and conducting enhanced due diligence when necessary.

Reporting Suspicious Activities
Tonil Trust Limited is committed to promptly detecting and reporting any suspicious activities that may indicate money laundering or terrorist financing. Employees are required to report such activities to the designated Compliance Officer, who will assess the situation and, if necessary, submit suspicious activity reports to the appropriate regulatory authorities.

Tonil Trust Limited maintains accurate and up-to-date records of all AML-related activities, including customer due diligence, transaction records, and internal reports. These records are securely stored and retained in accordance with applicable laws and regulations.

Internal Controls and Audit
Tonil Trust Limited establishes and maintains internal controls and procedures to ensure the effectiveness of our AML framework. Regular audits are conducted to assess compliance with policies, identify areas for improvement, and implement corrective measures when necessary.

Regulatory Cooperation
Tonil Trust Limited acknowledges the importance of cooperating with relevant regulatory authorities and law enforcement agencies. We will promptly respond to requests for information and provide assistance in investigations related to money laundering or terrorist financing.

Annual Review
This AML Policy will be reviewed on an annual basis or as required by changes in laws, regulations, or business operations. Updates and enhancements will be made as necessary to ensure its effectiveness.