01Purpose and legal framework
This policy summarises the anti-money-laundering and know-your-customer obligations that apply to NAVICELLA INVESTMENT TRUST and the manner in which they are discharged. It is a summary for information; it does not replace the Trust’s internal procedures or the law itself.
02A risk-based approach
Due diligence is calibrated to risk. Each relationship is assessed and classified, and the depth of verification, the seniority of approval and the frequency of review follow that classification.
Risk is assessed against, among other factors, the jurisdictions involved, the nature and complexity of the structure, the asset types held, the transparency of the ownership chain, the plausibility of the stated purpose, and whether any party is a politically exposed person.
03Customer due diligence
No relationship is established, and no assets are accepted, before due diligence is complete. There is no provisional onboarding.
Identification of the contracting party
- For a natural person: full name, date of birth, nationality, residential address and an official photographic identity document.
- For a legal entity: name, legal form, registered seat, register extract, constitutive documents and evidence of the authority of those acting.
- Verification against original or certified documentation, obtained from a reliable and independent source.
Purpose and nature of the relationship
The intended purpose of the structure, the expected pattern of activity and the origin of the assets are established and documented at the outset, and are tested against actual activity thereafter.
04Beneficial ownership
The beneficial owners — the natural persons who ultimately own or control the assets, or on whose behalf a transaction is conducted — are identified in every case, and their identity is verified. This includes settlors, beneficiaries, protectors and any person exercising effective control over the structure.
Ownership and control chains are followed to the natural persons at the end of them. A nominee, a corporate director or an intermediary entity is not accepted as the end of an enquiry.
Beneficial ownership information is recorded and reported to the competent Liechtenstein authorities as the law requires. It is not published on this website or made available to the public.
05Source of funds and source of wealth
Two distinct questions are asked, and both must be answered.
- Source of funds — the origin of the specific assets being placed into the structure.
- Source of wealth — how the contracting party’s overall wealth was accumulated.
Documentary evidence is required: sale agreements, audited accounts, tax filings, inheritance documents, distribution statements or equivalent. An explanation that cannot be evidenced to the standard the law requires will not be accepted, irrespective of the amount involved.
06Enhanced due diligence
Enhanced measures are applied where the risk classification requires it, including where a party is a politically exposed person, a family member or a close associate of one; where a high-risk third country is involved; where the ownership structure is unusually complex without evident commercial rationale; or where any element of the relationship departs from its stated purpose.
Enhanced measures include senior approval before establishing or continuing the relationship, additional independent verification of source of wealth, and more frequent review.
07Sanctions and screening
Parties to a relationship are screened against the sanctions and restrictive-measures regimes applicable in Liechtenstein, including measures adopted pursuant to United Nations and European Union resolutions. Screening is repeated on an ongoing basis, not only at onboarding.
A designated person or entity will not be onboarded, and an existing relationship will be frozen and reported where a designation occurs.
08Ongoing monitoring and records
Relationships are monitored throughout their life. Activity is tested against the documented purpose and expected pattern; material deviation triggers review, and documentation is refreshed periodically rather than left to age.
Due diligence records and transaction documentation are retained for the statutory period following the end of a relationship — not less than ten years — and are made available to the competent authorities on lawful request.
09Reporting suspicion
Where there is knowledge or a reasonable suspicion of money laundering, of a predicate offence, of organised crime or of terrorist financing, a report is made to the Financial Intelligence Unit in Vaduz as the law requires.
Such a report is made without notifying the party concerned. The statutory prohibition on tipping-off is observed strictly, and no confirmation will be given as to whether a report has or has not been made.
10Relationships that are declined
Some relationships are refused as a matter of policy, without negotiation:
- where the identity of a contracting party or beneficial owner cannot be verified;
- where the origin of the assets cannot be documented satisfactorily;
- where a party is subject to applicable sanctions;
- where the structure appears designed principally to obscure ownership;
- where the stated purpose is implausible or inconsistent with the activity proposed;
- where anonymous accounts, bearer instruments or shell arrangements without substance are requested;
- where assistance is sought in concealing income or assets from a competent tax authority.
A declined relationship is recorded, and the decision is not reopened on the basis of the size of the assets involved.
11Internal controls and training
A compliance and due diligence function is responsible for the application of this policy, with direct access to the trustee board. Duties are separated so that the person performing due diligence is not the sole person approving the relationship.
Officers and staff receive periodic training on due diligence obligations, on the recognition of suspicious circumstances, and on reporting duties. Internal procedures are reviewed against changes in law and guidance.
12Contact
Questions about this policy may be addressed in writing to the Trust at its registered office. Requests concerning personal data processed in the course of due diligence are handled under the Privacy Policy, subject to the restrictions that anti-money-laundering law places on disclosure.