AML & KYC Policy – Flair Financial Accounting

Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Effective Date: July 22, 2025

Flair Financial Accounting (“FlairFAS,” “we,” “us,” or “our”) is committed to preventing money laundering, terrorist financing, fraud, and illicit financial activity. This policy outlines our AML and KYC procedures in compliance with Nepalese law, FATF standards, and international best practices.

1. Policy Objectives

Prevent use of FlairFAS services for money laundering or illegal activities
Verify the identity of clients and beneficial owners
Monitor and report suspicious transactions
Maintain records and comply with regulatory obligations

2. Client Due Diligence (CDD)

All clients must undergo CDD before services are initiated. This includes:

Identity verification using government-issued ID or company registration documents
Collection of tax identification numbers, source of funds, and ownership structures
Risk-based assessment of client profile (low, medium, or high risk)

3. Enhanced Due Diligence (EDD)

For high-risk clients, additional measures are applied, such as:

In-depth verification of beneficial ownership
Source of wealth and fund tracing
Approval from senior management for onboarding
Ongoing transaction monitoring

4. Politically Exposed Persons (PEPs) & Sanctions Screening

We screen all clients against:

Global sanctions lists (e.g., UN, OFAC, EU)
PEP databases to assess risks of political influence or corruption
Watchlists related to terrorism financing and financial crime

5. Ongoing Monitoring

Once onboarded, client activities and transactions are continuously reviewed for:

Unusual behavior or inconsistent financial patterns
Large or frequent cash transfers without clear purpose
Activities across high-risk jurisdictions

6. Suspicious Transaction Reporting (STR)

If suspicious behavior or a red-flag transaction is identified:

FlairFAS will document and escalate the incident
A report may be submitted to Nepal’s Financial Information Unit (FIU) or other legal authorities as required
The client may be suspended or disengaged based on severity

7. Record Keeping

We retain AML/KYC records for a minimum of five (5) years after the conclusion of the client relationship. These include:

Identification documents
Transaction history
Internal compliance reviews and correspondence

8. Employee Training & Compliance Oversight

All FlairFAS team members receive AML/KYC training upon hiring and annually thereafter
Internal compliance officers oversee implementation, updates, and case investigations
Our firm adheres to a “zero-tolerance” approach for non-compliance

9. Regulatory Alignment

Our policy aligns with:

Nepal Rastra Bank directives and national AML legislation
FATF recommendations
Donor requirements for NGOs, INGOs, and cross-border transactions

10. Contact Us

If you have questions about our AML/KYC practices:

Flair Financial Accounting

Email: policy@flairfas.com

Website: https://flairfas.com

Frequently asked questions

Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

1. Why does FlairFAS require ID and company documents?

To comply with AML laws and verify the legitimacy of all clients, including source of funds and ownership.

2. What is considered suspicious activity?

Examples include large unexplained cash transactions, use of shell entities, inconsistent behavior with known client profiles, or transfers from sanctioned countries.

3. Is my data secure during verification?

Yes. All verification documents are securely stored and encrypted in accordance with our Data Protection & Security Policy.

4. What happens if I fail KYC checks?

If we cannot verify your identity or detect a risk of money laundering, we may decline or terminate the engagement.

5. Does FlairFAS report suspicious transactions?

Yes. If we identify a red flag, we are obligated to file reports with Nepal’s Financial Information Unit or relevant authority, as required by law.

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