Compliance at Swiss Quantum Finance

Our commitment

Swiss Quantum Finance AG ("SQF") operates a compliance-led business. As a Swiss financial intermediary within the meaning of Article 2 paragraph 3 of the Swiss Anti-Money Laundering Act (AMLA), affiliated with SO-FIT, a self-regulatory organisation recognised by the Swiss Financial Market Supervisory Authority (FINMA), SQF applies a documented, risk-based framework for the prevention of money laundering, terrorist financing, sanctions evasion and fraud across all of its services — multi-currency accounts, cross-border payments, foreign exchange, merchant collection and digital asset services.

No client may access SQF's services until the required onboarding and compliance review has been completed and approved. Growth never takes priority over compliance quality.

Client onboarding and due diligence

Before opening any account or business relationship, SQF conducts a compliance review which includes, as applicable:

• Identification and verification of the contracting party — KYC for natural persons and KYB for legal entities, including constitutional documents, commercial register extracts and ownership structure;
• Beneficial ownership — identification and verification of the natural persons who ultimately own or control the client. If beneficial ownership cannot be established to our satisfaction, we will not open the relationship;
• Screening of clients, beneficial owners, controlling persons and authorised signatories against sanctions lists, politically-exposed-person (PEP) registers, watchlists and adverse media;
• Business profile — the client's business rationale, expected transaction activity, currencies, corridors, counterparties and volumes;
• Source of funds — and, where required by the risk profile, source of wealth;
• Risk assessment — every client is assigned a documented risk category, which determines the depth of due diligence and the frequency of periodic review;
• Enhanced due diligence for relationships presenting increased or higher risk, with senior-management approval where required.

Ongoing monitoring

Compliance does not stop at onboarding. SQF performs:

• Transaction monitoring of fiat, FX, payment, merchant collection and digital asset activity against the approved client profile, using risk-based thresholds and alert rules;
• Ongoing screening — clients and related parties are re-screened against sanctions, PEP, watchlist and adverse-media sources on an ongoing and event-driven basis;
• Periodic reviews of every client file at a frequency determined by the client's risk category, and event-driven reviews whenever there is a material change in ownership, control, business activity or risk profile;
• Blockchain analytics for digital asset activity, including wallet risk screening and, where applicable, collection and transmission of originator and beneficiary information in line with applicable "Travel Rule" requirements.

Clients may be asked to provide supporting documentation for specific transactions — such as invoices, contracts, counterparty details or source-of-funds evidence. Responding promptly helps us process transactions without delay. SQF may delay, decline, restrict or return a transaction where required information is not provided or where the activity is inconsistent with the approved profile.

What we will not accept

SQF will not knowingly onboard, maintain or process transactions involving:

• sanctioned persons or entities, or persons owned or controlled by them;
• prohibited jurisdictions under applicable sanctions or SQF's risk appetite;
• clients whose beneficial ownership cannot be verified;
• unexplained source of funds or unclear economic rationale;
• unlicensed financial services activity;
• digital asset activity linked to prohibited typologies, including mixers and tumblers, darknet markets, ransomware, hacks, scams, terrorism financing or sanctioned addresses.

Reporting obligations

Where SQF knows or has reasonable grounds to suspect money laundering, terrorist financing or related criminal activity, it is legally required to report to the Swiss Money Laundering Reporting Office (MROS) and to cooperate with the competent authorities. Swiss law prohibits SQF from informing a client that such a report has been or may be filed.

Recordkeeping

SQF retains client identification, due diligence and transaction records for at least ten years after the end of the business relationship or completion of the transaction, as required by the AMLA. Records are stored securely and remain retrievable for audit and supervisory purposes. This statutory retention duty takes precedence over deletion requests for the records concerned (see our Privacy Policy).

Governance

SQF's Board of Directors and Management carry ultimate responsibility for the AML/CTF framework. Day-to-day compliance oversight is performed by SQF's designated AMLA/Compliance Officer function, supported by trained staff and specialised compliance technology. SQF's framework is subject to periodic audit through its SRO affiliation.

Questions

For compliance-related questions about onboarding or documentation requirements, contact your relationship manager or admin@swissquantumfinance.com.