As a Swiss financial intermediary, Evanera AG, Sennweidstrasse 45, 6312 Steinhausen, Switzerland ("Evanera", "we", "us") must strictly adhere to the Swiss anti-money laundering laws and, as a member of the self-regulatory organization VQF (Financial Services Standards Association), to the VQF regulations. VQF itself as a self-regulatory organization is approved by the Swiss Financial Market Supervisory Authority ("FINMA") and periodically assesses our compliance with applicable laws and regulations through an external audit report.
    Evanera does not accept assets stemming from, nor does it start business relationships with persons connected to, money laundering, financing of terrorism, or qualified tax fraud, even if such crimes were committed abroad.
    Therefore, we have adapted applicable AML laws and regulations by passing an internal compliance & AML policy. This AML/KYC Customer Information intends to provide our customers ("Customer", "you", "your", or "yours") with a general overview of the procedures and rules applicable when using our services, as further laid out in our terms and conditions. Therefore, this document is for informational purposes only and does not require your approval or consent. Applicable laws and Evanera's internal policies are subject to change without prior notice.
    As a principle, we must establish our Customers' identity by obtaining specific information about each Customer and verifying this information utilizing one (or several) documents of evidentiary value. We may do so directly or by employing third-party service providers. From time to time, we may require Customers to submit updated information or documents and to confirm that previously provided information is still valid.
    Parts of the identification process use audiovisual means, which may be subject to separate terms and conditions defined by third-party service providers. If the audiovisual identification process cannot be completed, the process is stopped, and the Customer in question cannot use our services.
    We do not enter into business relationships with domiciliary companies, associations, trusts, foundations, insurance wrappers, or similar structures. Further, completing the identification process does not give prospective Customers any right to use our services. We may deny persons our services at our discretion, and particularly where a person appears on international sanctions lists, qualifies as a politically exposed person, or where a relationship with a person bears an increased AML risk.
    Applicable laws compel us to notify the Swiss Money Laundering Reporting Office (MROS), where we know or have reasonable grounds to suspect that assets involved in a business relationship
    • are connected to an offence in terms of art. 260ter no. 1 or 305bis Swiss Criminal Code ("SCC");
    • are the proceeds of a criminal act or a qualified tax offense according to art. 305bis no. 1bis SCC; or
    • are subject to the power of disposal of a criminal organization or serve the financing of terrorism (art. 260quinquies paragraph 1 SCC).
    Furthermore, we must notify MROS if we deny access to our services based on reasonable suspicions regarding the crimes cited above and if data submitted to us by VQF or FINMA correspond with data of a Customer or a transaction processed by us. We may also choose to notify MROS without having a statutory obligation to do so.
  4. Last update: 1 July 2021