AML/CTF Compliance Framework
Sigma Horizons S.R.O. is committed to maintaining the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance in accordance with Czech and European Union regulations.
Company Name
SIGMA HORIZONS S.R.O.
Registration Number (ICO)
22206485
Registered Address
Varsavska 715/36, Vinohrady (Praha 2), 120 00 Praha
Jurisdiction
Czech Republic, European Union
Compliance Framework Overview
Our AML/CTF framework is designed to prevent, detect, and report suspicious activities while ensuring full compliance with applicable laws and regulations.
Comprehensive KYC procedures to verify customer identity and assess risk levels.
Real-time monitoring systems to detect unusual patterns and suspicious activities.
Automated screening against global sanctions lists and PEP databases.
Structured risk assessment and escalation procedures for identified threats.
Customer Due Diligence (CDD)
All customers are required to complete identity verification before accessing our services. Our standard CDD process includes:
- Government-issued photo identification (passport, national ID, or driver's license)
- Proof of address documentation (utility bill, bank statement, or official correspondence dated within 3 months)
- Biometric verification through facial recognition technology via Didit KYC
- Email and phone number verification
- Source of funds declaration for transactions exceeding EUR 1,000
Enhanced measures are applied when higher risks are identified:
- Customers from high-risk jurisdictions as defined by FATF
- Politically Exposed Persons (PEPs) and their close associates
- Transactions exceeding EUR 15,000 or equivalent
- Complex or unusual transaction patterns
- Customers with adverse media findings
EDD Additional Requirements:
- - Additional identity documentation
- - Detailed source of wealth verification
- - Senior management approval for onboarding
- - Enhanced ongoing monitoring
Customer information and risk profiles are reviewed on a regular basis:
12
Months - Standard Risk Review
6
Months - Medium Risk Review
3
Months - High Risk Review
Transaction Monitoring
We employ a combination of automated systems and manual review processes to monitor all transactions:
Automated Monitoring
- - Real-time transaction screening
- - Pattern recognition algorithms
- - Velocity checks and limits
- - Blockchain analytics integration
Manual Review
- - Alert investigation and disposition
- - Complex case analysis
- - Quality assurance reviews
- - Escalation handling
Transaction-Based
- Structuring transactions to avoid thresholds
- Rapid movement of funds (layering)
- Transactions inconsistent with customer profile
- High-volume activity from new accounts
- Transactions with high-risk jurisdictions
Behavioral
- Reluctance to provide required information
- Frequent changes to account details
- Use of multiple accounts for no apparent reason
- Transactions with no clear economic purpose
- Unusual interest in compliance procedures
| Verification Level | Daily Limit | Monthly Limit | Requirements |
|---|---|---|---|
| Basic | EUR 1,000 | EUR 5,000 | Email + Phone verification |
| Standard | EUR 10,000 | EUR 50,000 | Full KYC (ID + Address) |
| Enhanced | EUR 50,000+ | Custom | EDD + Source of Wealth |
Sanctions and PEP Screening
All customers and transactions are screened against comprehensive sanctions databases:
EU Sanctions List
European Union consolidated list
UN Sanctions
United Nations Security Council
OFAC SDN List
US Treasury Department
UK Sanctions
HM Treasury consolidated list
FATF Lists
High-risk and monitored jurisdictions
Local Lists
Czech national sanctions
Sanctions matches result in immediate account freezing and regulatory reporting.
We screen all customers against PEP databases and apply enhanced measures when identified:
PEP Categories Screened:
- - Heads of state and government officials
- - Senior politicians and party officials
- - Senior judicial and military figures
- - Senior executives of state-owned enterprises
- - Family members of PEPs
- - Close associates of PEPs
Enhanced Measures for PEPs:
- 1. Senior management approval required for account opening
- 2. Enhanced source of wealth and funds verification
- 3. Ongoing enhanced monitoring of all transactions
- 4. Annual relationship review at minimum
Customers are screened for adverse media coverage related to:
Risk Assessment, Mitigation & Escalation
Each customer is assigned a risk rating based on multiple factors:
Customer Risk Factors
- Customer type (individual/corporate)
- Country of residence/incorporation
- Occupation/business activity
- PEP status
- Source of wealth
Transaction Risk Factors
- Transaction volume and frequency
- Geographic exposure
- Payment methods used
- Cryptocurrency types
- Counterparty risk
Low Risk
Standard CDD, periodic reviews (annual), automated monitoring
Mitigation: Standard verification, regular screening updates
Medium Risk
Enhanced monitoring, semi-annual reviews, additional documentation
Mitigation: Transaction limits, enhanced screening, closer monitoring
High Risk
Full EDD, quarterly reviews, senior management oversight, real-time monitoring
Mitigation: Strict limits, manual transaction approval, continuous surveillance
Alert Generation
ImmediateAutomated systems or manual observation identifies suspicious activity
Level 1 Review
Within 24 hoursCompliance analyst reviews alert and gathers additional information
Level 2 Escalation
Within 48 hoursSenior compliance officer reviews substantiated alerts
SAR Decision
Within 72 hoursMLRO determines if Suspicious Activity Report is required
Regulatory Filing
As per regulationsSAR filed with Financial Analytical Unit (FAU) if required
All records are maintained in accordance with Czech AML law and EU regulations:
- Customer identification documents - 5 years after end of relationship
- Transaction records - 5 years from date of transaction
- Risk assessments - Duration of relationship + 5 years
- SAR filings and related documentation - 5 years minimum
- Training records - 5 years after employee departure
Questions About Our Compliance Program?
If you have any questions about our AML/CTF policies or need to report suspicious activity, please contact our compliance team.
Compliance Contact: contact@sigma-horizon.xyz
This AML/CTF Compliance Framework was last updated on January 2026. Sigma Horizons S.R.O. reserves the right to update these policies as required by regulatory changes.