Effective Date: August 2025

Havenbach is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance. As part of our global mobility and investment migration services, we implement Anti-Money Laundering (AML) and Know Your Customer (KYC) procedures in line with international best practices and applicable legal requirements.

1. Purpose

Our AML/KYC measures are designed to:

• Prevent the misuse of our services for money laundering, terrorism financing, or other illicit activity

• Verify the identity and legitimacy of clients and applicants

• Comply with regulations in jurisdictions where we operate (EU, GCC, etc.)

2. Identity Verification

Before entering into a client relationship or submitting applications on a client’s behalf, Havenbach may require:

• Valid government-issued identification (passport, national ID)

• Proof of residence or legal address

• Source of funds and/or source of wealth documentation

• Additional information or documents as required by law or program guidelines

Documents must be current, valid, and legible. We reserve the right to request notarized or certified copies.

3. Due Diligence

Depending on the type of service or jurisdiction, we may perform:

• Standard Due Diligence (SDD)

• Enhanced Due Diligence (EDD) for high-risk clients or politically exposed persons (PEPs)

All due diligence is conducted confidentially and in accordance with data protection regulations, including the EU General Data Protection Regulation (GDPR).

4. Recordkeeping & Retention

We retain all AML/KYC records for the period required by law (typically five to ten years), including:

• Client identification documents

• Internal due diligence reports

• Application documentation and correspondence

These records are stored securely and accessed only by authorized personnel.

5. Refusal or Termination of Services

Havenbach reserves the right to refuse service or terminate an existing engagement if:

• A client refuses to provide required documentation

• False or misleading information is submitted

• There is suspicion of fraudulent, criminal, or sanctionable activity

We are legally required to report certain cases to appropriate authorities without prior notice.

6. Contact

For questions about our AML/KYC policy or compliance process:

📧 Email: [email protected]
📞 Phone (GR): +30 698 3200 953
📞 Phone (AL): +355 68 60 80 345

We thank you for your cooperation and for helping us uphold safe and responsible global service delivery.