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Declaration regarding AML, CTF and KYC within Thomas-Walther Limited


Thomas-Walther has made it a priority to combat and prevent money laundering and terrorist financing through our Company. Thomas-Walther prides itself of being able to identify and understand risks of money laundering and terrorist financing in order to apply preventive measures through its Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF) policies and procedures, which are in line with the Financial Action Task Force on money laundering (FATF) and international standards.


In light of our changing environment, Thomas-Walther continually evaluates the strength and relevance of its existing policies, procedures and employee training programs and, if necessary, updates them to address these changes.


Below is a summary of what Thomas-Walther AML and CTF policies and procedures include:

  1. Thomas-Walther has a legal and regulatory compliance program that  includes a designated officer that is responsible for coordinating and  overseeing the AML framework.
  2. Proper Know-Your-Client (KYC) practices are central, and the knowledge of the client provides a basis for understanding the general activities in which a client usually would be expected to engage.
  3. Thomas-Walther developed written policies documenting the processes in place to prevent, detect and report suspicious transactions.
  4. In addition to welcoming inspections by government supervisors/regulators, Thomas-Walthers’ internal audit and external auditors assess AML policies and practices on a regular basis.
  5. Thomas-Walther has a policy prohibiting accounts/relationships with shell banks.
  6. Thomas-Walther has policies covering relationships with Politically Exposed Persons (PEP), their family and close associates.
  7. Thomas-Walther has a risk-based assessment of its client base and their transactions.


All clients are screened against the Special Investigation Commission (SIC) list, and international lists on Complinet:

  1. Sanctions List (including but not limited to Service d’Information et de Contrôle sur les Circuits Financiers; European Union; HM Treasury (formally Bank of England); Office of Foreign Assets Control (OFAC), United States; United Nations Security Council Committee; US Department of State.)
  2. Law Enforcement Lists (including but not limited to City of London Police UK; Federal Investigation Agency; Federal Bureau of Investigation (FBI) United States; Interpol; National Crime Squad UK; Serious Organized Crime Agency; US Air Force Office of Special Investigations; US Drug Enforcement Administration; US Secret Service; Combined Forces Special Enforcement Unit-British Columbia (CFSEU-BC), Canada…)
  3. Regulatory Enforcement Lists (Asia/Pacific enforcement bodies; European enforcement bodies; North American enforcement bodies; Latin American/Caribbean enforcement bodies; UK enforcement bodies)
  4. Other Bodies (Companies House – Disqualified Directors; World Bank – Debarred Parties; Lloyd’s Register – Fairplay)
  5. High Profile Persons Data and Dow Jones Database for high-ranking government officials and PEP.


Thomas-Walther is fully informed of the laws and regulations governing its correspondents abroad and deals with them in compliance with such laws and regulations. Thomas-Walther is committed to abide by the laws, regulations, procedures, sanctions and restrictions adopted by international legal organizations and/or by the sovereign authorities in the correspondents’ home countries, including but not limited to, bills passed by the U.S. congress.


Thomas-Walther does not deal with or facilitate transactions or provide consultancy or facilitating services to entities designated as terrorist or criminal organizations by local authorities, international organizations and sovereign authorities in countries where it maintains correspondent accounts. Furthermore, Thomas-Walther does not deal with or facilitate transactions or provide consultancy or facilitating services to a person if it has any suspicion that this person is acting on behalf of, or is owned or controlled by such designated entities and refrains from facilitating transactions or provide consultancy or facilitating services if it suspects that such transactions or provide consultancy or facilitating services are linked to such designated entities or any criminal and/or terrorist activity.

Know Your Rights and Responsibilities


Client’s Rights
  1. You have the right to courteous service – from your consultant and facilitator and all other associates/partners of our firm
  2. To take understanding of the terms, conditions, and details of the service, and to request ample explanations to be sure that you as a client have understood them and can abide by them.
  3. To obtain a clear, sufficient and simplified explanation about the consultancy and facilitating services.
  4. To obtain a professional and clear answer to any question concerning any ambiguous clauses or conditions.
  5. You have the right to open, consistent communication and to have information presented in writing and in a clear and understandable term.
  6. To request to read and obtain in advance a copy of each document and text referred to in any contract to be signed with Thomas-Walther or any other of their clients.
  7. To obtain and retain a copy of the contracts, agreements and documents signed by yourself, without bearing any additional cost.
  8. To request Thomas-Walther to determine the actual cost of their service.
  9. To obtain any consultancy and facilitating services, provided it is suitable with your and Thomas-Walther needs, profile and perception and all international and domestic legislation.
  10. To obtain, for each consultancy and facilitating service, a regular written update of the transactions position.
  11. To refuse to sign a blank or incomplete form and make sure all the required fields and figures in the form to be signed by you are correct and complete.
  12. To have only one primary contact within Thomas-Walther and not to be dealing with multiple contacts within the company
  13. You have the right to have any errors corrected fully and any complaints addressed promptly.
  14. You have the right to strict confidentiality, complete discretion and full protection of your personal and financial information. We do not sell your information to anyone. Thomas-Walther only provides information to external organizations when required by law or regulation or when necessary to provide the services you have requested. Unless you specify otherwise, Thomas-Walther’ subsidiaries may share your information within the Thomas-Walther organization to provide informed, efficient service.
  15. You have the right to talk directly to all principles who are already clients of Thomas-Walther regarding your transaction and as soon as convenient with all parties concerned. Thomas-Walther does not accept or use ‘broker Chains’. Thomas-Walther is always one away from the principle or direct to the principle – as no other solution is viable or workable.
  16. Any verbal communication by Thomas-Walther must/will be supported by a confirmation e-mail, outlining all points, requirements, agreements and/or expectations to ensure clear and concise communication (Skype or other social media is not acceptable)


Client’s Duties
  1. Provide true, complete and accurate information when filling out any form or reasonable request made by Thomas-Walther, and refrain from providing any false information.
  2. Update the personal information submitted to Thomas-Walther, on a continuous basis and whenever required to do so.
  3. Comply with the terms, conditions, policies and procedures governing the chosen consultancy and facilitating service.
  4. Provide Thomas-Walther with your home address, work address, email, ordinary mail, and telephone number, and report any change in this information to enable Thomas-Walther to contact you personally and thus guarantee the privacy of information. This information can be given in the Thomas-Walther initial application KYC
  5. Maintain good, clear and regular verbal and written communication with the Thomas-Walther allocated contact
  6. You have the responsibility to seek the advice of a tax professional, CPA or attorney, as appropriate. Financial and investment planning inherently involve potential tax and legal implications. However, Thomas-Walther do not practice as lawyers or CPAs and cannot give specific legal or tax advice.
  7. ALL introducers and principles MUST complete and/or have reasonable and tangible due diligence accomplished and passed before introducing any individual or non-individual entity to Thomas-Walther
  8. Any verbal communication by yourself must be supported by a confirmation e-mail, outlining all points, requirements, agreements and/or expectations to ensure clear and concise communication (Skype or other social media is not acceptable)
Instructions to the Client


  1. Do not provide any other party, under any circumstances, with any details about your bank account or any other banking or critical personal information. All requests for any type of personal information will be request through the company e-mail only, please feel free to contact your Thomas-Walther representative for clarification for the reason behind the request
  2. You have the responsibility to protect your personal and private information, including statements, login names and account passwords, in order to ensure the security of your financial and personal data. Thomas-Walther and associates will not ask you for your password, and you should not give this information to anyone you do not want to have access to your account.
  3. If ever facing financial difficulties or issues with performing or meeting your commitments/obligations, please notify Thomas-Walther in order to find out your best options.
  4. Be careful when granting a proxy to a third party to complete your banking and financial transactions, by clearly determining the powers delegated under this proxy.
  5. All communication via and form of media including but not exclusive to e-mail, telephone, fax, skype or any other media is strictly confidential and cannot be discussed or share with anyone except the recipient of that communication unless legally entitled to do so or previously agreed.
Initial Procedures for becoming a Thomas-Walther Client
  1. Initial contact e-mail from client
  1. Conference call arranged for introduction of parties and an informal discussion of clients requirements, expectations and/or services provided, this will also cover the type of consultancy and facilitating services Thomas-Walther can and cannot provide (Within two banking days of point one)
  1. Client will send a formal e-mail to Thomas-Walther outlining clients exact requirements and expectations: (Within two banking days of point two)
  • Thomas-Walther responds to the above e-mail with a refusal or an acceptance and/or a request for any other information they deem necessary or that needs to be clarified.(Within one banking days of point three)
  1. Thomas-Walther issues: (Within one banking days of three point one)
  • Thomas-Walther company profile
  • Thomas-Walther initial application KYC
  • Thomas-Walthers terms and conditions
  • Thomas-Walther client solution proposal
  1. Client returns signed, completed and additional documentation as listed below*: (Within five banking days of point four)
  • Thomas-Walther company profile
  • Thomas-Walther initial application KYC
  • Thomas-Walthers terms and conditions
  • Clients company profile and/or individual bio

*If any of the above documentation is not fully completed or supplied Thomas-Walther is unable to accept the client and all communication and/or previous agreements/verbal confirmations are null and void

When due diligence is completed and passed by the client. (Within fifteen banking days of point five)

  1. Thomas-Walther will then contact the client again to commence the consultancy and facilitating service byThomas-Walther issuing:
  • Thomas-Walther consultancy and facilitating agreement (Within two banking days of DD acceptance)
  1. Client returns signed and completed:
  • Thomas-Walther consultancy and facilitating agreement (Within five banking days of point six point one)

Consultancy and facilitating commences (Within five banking days of point seven point one)