AML Policy

Surge Trust Bank is committed to the highest standards of the Anti-Money Laundering (AML) compliance and Anti-Terrorist Financing and requires the management, and employees to follow the named standards. Money laundering – the process of converting funds, received from illegal activities (such as fraud, corruption, terrorism, etc.), into other funds or investments that look legitimate to hide or distort the real source of funds.

The process of money laundering can be divided into three sequential stages: 

  • Placement. At this stage, funds are converted into financial instruments, such as checks, bank accounts, and money transfers, or can be used for purchasing high-value goods that can be resold. They can also be physically deposited into banks and non-bank institutions (e.g., currency exchangers). To avoid suspicion by the company, the launderer may as well make several deposits instead of depositing the whole sum at once, this form of placement is called smurfing. 
  • Layering. Funds are transferred or moved to other accounts and other financial instruments. It is performed to disguise the origin and disrupt the indication of the entity that made multiple financial transactions. Moving funds around and changing in their form makes it complicated to trace the money being laundered.
  • Integration. Funds get back into circulation as legitimate to purchase goods and services.

 

Anti-Money Laundering (AML) policy

Surge Trust Bank, like most banks providing services on the financial market, adheres to the principles of Anti-Money Laundering and actively prevents any actions that aim or facilitate the process of legalizing or illegally gaining funds. AML policy means preventing the use of the company's services by criminals, with the aim of money laundering, terrorist financing or other criminal activity. 

For this purpose, a strict policy on the detection, prevention and warning of the corresponding bodies of any suspicious activities was introduced by the company. Moreover, Surge Trust Bank has no right to report to clients that the law enforcement bodies are informed on their activity. A complex electronic system for identifying every client and conducting a detailed history of all operations was introduced as well. 

To prevent money laundering, Surge Trust Bank reserves the right to suspend any client's operation, which can be regarded as illegal or, may be related to money laundering in the opinion of the staff.

 

Know Your Customer and Due Diligence

Due to the Bank’s commitment to the AML and KYC policies, each Client of the Surge Trust Bank has to finish the verification procedure. Before the Bank starts any cooperation with the Client, Surge Trust Bank ensures that the satisfactory evidence is produced or such other measures are taken as will produce satisfactory evidence of the identity of any customer or counterparty. The Bank as well applies heightened scrutiny to Clients, who are residents of the countries, identified by credible sources as countries, having inadequate AML standards or may represent high risk for crime and corruption and to beneficial owners who reside in and whose funds are sourced from named countries.

 

Monitoring of client activity

In addition to gathering information from the clients, Surge Trust Bank continues to monitor the activity of every client to identify and prevent any suspicious transactions. A suspicious transaction is known as a transaction that is inconsistent with the client's legitimate business or the usual client's transaction history known from client activity monitoring. Surge Trust Bank has implemented the system of monitoring the named transactions (both automatic and, if needed, manual) to prevent using the bank's services by criminals.

 

Deposit and withdrawal requirements

All the clients' operations to deposit and withdraw funds have the following requirements: 

  • In case of bank transfer or transfer from a bank card, the name indicated during the registration must match the name of the owner of the account/bank card. 

  • Withdrawing funds from the account via the method, which is different from the depositing method, is possible solely after withdrawing the sum, which is equal to the sum of client's deposits via the method and to the same account used for depositing.
     
  • If the account was credited in the way that cannot be used for funds withdrawal, the funds may be withdrawn to a bank account of the client or any other way may be used, as agreed with the Company with the help of which the Company is able to prove the identity of the account owner.

  • If the account has been credited with funds through various payment systems, funds withdrawal shall be made on a pro rata basis commensurate to the size of each deposit. 

  • In case of depositing via Visa/MasterCard, Wire Transfer, the withdrawal of funds, which exceed the sum of the client's deposits, is possible via any of the following methods: Visa/MasterCard, Wire Transfer. In case of depositing via another method, the withdrawal of funds that exceed the sum of the client's deposits, is possible via any available method, by the client's choice.