Compliance
CyTaka Compliance
CyTaka / Globus Research & Development UK Ltd
Anti-Money Laundering (AML), Anti-Bribery & Corruption (AB&C), and Sanctions Policy
1. Introduction
This document outlines the policies and procedures followed by CyTaka / Globus Research & Development UK Ltd ("CyTaka") to ensure compliance with applicable Anti-Money Laundering (AML), Anti-Bribery and Corruption (AB&C), and Sanctions regulations. It is vital that all employees, consultants, and third-party partners adhere to this policy without exception.
2. Legal and Regulatory Framework
CyTaka adheres to the following key laws and regulations: United Kingdom:
- The Proceeds of Crime Act 2002 (POCA)
- Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended)
- Bribery Act 2010
- Sanctions and Anti-Money Laundering Act 2018
International Regulations (where applicable):
- Financial Action Task Force (FATF) Recommendations
- European Union Sanctions Lists
- U.S. Office of Foreign Assets Control (OFAC)
- UN Sanctions
3. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)
3.1 Customer Due Diligence (CDD)
CDD is conducted on all clients prior to establishing a business relationship. The following information is collected and verified:
- Full legal name
- Date of birth (for individuals) or incorporation (for companies)
- Address
- Source of funds
- Nature of the business relationship
- Identity of beneficial owners (if applicable)
3.2 Enhanced Due Diligence (EDD)
EDD is applied where higher risk is identified. Situations requiring EDD include:
- Politically Exposed Persons (PEPs)
- Clients from high-risk jurisdictions
- Unusual or complex transaction patterns
- Large one-off transactions outside of expected behaviour
EDD includes all CDD measures plus:
- Verification of source of wealth
- Additional documentation for identity
- Senior management approval before onboarding
- Closer ongoing monitoring
4. Politically Exposed Persons (PEPs)
PEPs and their close associates/family members receive additional scrutiny. This includes:
- Mandatory EDD
- Documented senior management approval for onboarding
- Periodic review of the relationship
- Monitoring for unusual transactions
- Identification using reliable third-party PEP databases
5. Gifts, Hospitality and Conflicts of Interest To ensure full AB&C compliance:
- Gifts or hospitality must not exceed £100 per individual per instance unless approved by senior management
All gifts and hospitality must be:
- Proportionate
- Transparent
- Logged in the company gift register
- Offering or receiving bribes in any form is strictly prohibited
- Employees must report any potential conflict of interest or inappropriate offer immediately
6. Sanctions Compliance CyTaka does not engage with:
- Individuals or entities on any national/international sanctions list
- Jurisdictions under comprehensive international sanctions
- Transactions routed through sanctioned banks or territories
All clients and transactions are screened against updated sanctions lists. Any potential match is escalated to the Compliance Officer for immediate review and action.
7. Ongoing Monitoring of Clients and Transactions
CyTaka applies a risk-based approach to ongoing monitoring. Monitoring includes:
- Automated transaction monitoring using thresholds and alerts for unusual patterns
- Periodic client reviews based on risk level (e.g., annually for high-risk, every 3 years for low-risk)
- Real-time sanctions screening
- Review of trigger events, such as change of ownership, significant change in transaction behaviour, or updated sanctions alerts
Suspicious activities are reported internally and externally via Suspicious Activity Reports (SARs) as required under POCA.
8. Training and Awareness
All staff receive mandatory training on AML, AB&C, and sanctions compliance:
- At induction
- Annually
- Upon updates to regulation or policy
9. Roles and Responsibilities
- Compliance Officer: Oversees policy implementation, reporting, and regulatory engagement
- All Staff: Must comply with this policy, report suspicious activity, and complete required training
CyTaka / Globus Research & Development UK Ltd Compliance & Ethics Statement
At CyTaka / Globus Research & Development UK Ltd, we are fully committed to conducting our business with the highest standards of integrity, transparency, and accountability. We adhere to strict Anti-Money Laundering (AML), Anti-Bribery & Corruption (AB&C), and international sanctions compliance protocols in line with UK and global regulations.
Our Commitment
CyTaka complies with the following regulations:
- UK Proceeds of Crime Act 2002
- Money Laundering Regulations 2017 (as amended)
- UK Bribery Act 2010
- Sanctions and Anti-Money Laundering Act 2018
- Applicable international guidelines including FATF, UN, EU, and OFAC sanctions regimes
Client Due Diligence
We conduct robust due diligence on all clients, partners, and counterparties. Enhanced due diligence (EDD) measures are applied where higher risks are identified, including dealings with Politically Exposed Persons (PEPs) and entities from high-risk jurisdictions.
Anti-Bribery & Gifts
We maintain a zero-tolerance approach to bribery and corruption. Any gifts or hospitality must be reasonable, proportionate, and fully documented.
Sanctions Screening
All clients and transactions are screened against up-to-date international sanctions lists. We do not engage with any party subject to sanctions or based in a sanctioned jurisdiction.
Ongoing Monitoring
We continuously monitor relationships and transactions using both automated and manual review processes to ensure compliance with evolving regulations and to detect suspicious activity.
Training and Culture
Our team is regularly trained on compliance obligations, helping maintain a culture of integrity and vigilance.
For further information or compliance inquiries, please contact our Compliance Team at info@cytaka.com.
