Anti-Money Laundering & Counter Financing of Terrorism (AML/CFT) Policy
KARYU estate (the "Company") positions the prevention of money laundering and terrorist financing (AML/CFT) in global real estate transactions as one of our most critical management priorities. To protect the transparency of the international financial system and the real estate market, we execute our business based on the following strict policy.
1. Rigorous Know Your Customer (KYC) & Ultimate Beneficial Owner (UBO) Identification
Prior to the commencement of any transaction, the Company conducts rigorous identity verification (KYC) on sellers, buyers, and co-investors. When a corporation is a party to the transaction, we strive to identify not only the superficial corporate name but also the Ultimate Beneficial Owner (UBO) behind it, confirming its legality.
2. Elimination of Third-party Payments
To physically block illicit fund movements, for all financial settlements and advisory fee receipts involving the Company, we exclusively handle bank transfers from "lawful financial institution accounts strictly under AML regulations that perfectly match the client's own name." Transfers from third-party names, including relatives, acquaintances, and affiliated companies, are strictly refused under any circumstances, unless there is a rational reason and prior approval.
3. No-Cash Policy
Under no circumstances (including the receipt or payment of earnest money) will we handle cash in any transaction, unless there is a rational reason and prior approval. By restricting transactions exclusively to wire transfers through the aforementioned personal accounts, we guarantee the traceability of funds.
4. Source of Wealth/Funds (SoW/SoF) & Enhanced Due Diligence (EDD)
We evaluate the nature of the transaction, the client's country/region of residence, and the complexity of the scheme to take risk-appropriate measures. In transactions involving Politically Exposed Persons (PEPs), opaque offshore corporations, or large-scale fund transfers by High-Net-Worth Individuals (HNWI), we require rational explanations and supporting documentation regarding the Source of Wealth (SoW) and Source of Funds (SoF).
5. Right of Refusal
When verification is deemed necessary based on laws and our compliance standards, if a client refuses to provide information or rational explanations regarding the source of funds, or is uncooperative with our requests, we will immediately suspend all business services.
6. Suspicious Activity Reporting (SAR)
The Company confirms all KYC and transaction legality in compliance with international professional ethics. Should we recognize any suspicious points regarding the source of funds or economic rationality (suspicious activity) during the transaction process, we will promptly refuse the transaction without compromising for commercial interests and report it to the supervisory authorities in accordance with relevant laws.