AML and KYC Information

1. Our approach

Roca VC Limited is committed to preventing its products, platforms, relationships, and infrastructure from being used for money laundering, terrorist financing, fraud, sanctions evasion, corruption, trafficking, proliferation financing, market abuse, or other financial crime.

We maintain risk-based anti-money-laundering and customer due-diligence controls appropriate to the services provided and the legal requirements that apply. This page provides a public summary. It does not disclose confidential monitoring rules, investigation methods, reporting thresholds, or internal risk models.

2. Applicable framework

Depending on the contracting entity, activity, and jurisdiction, Roca VC Limited may apply requirements derived from:

• United Kingdom anti-money-laundering legislation;
• United Kingdom sanctions requirements;
• International sanctions;
• Financial Action Task Force principles;
• Regulatory guidance;
• Banking and payment-provider requirements; and
• Internal financial-crime risk policies.

Publication of this page does not itself mean that Roca VC Limited is authorised or licensed by a financial regulator. Any licence or registration held by the company will be identified separately on the Legal and Regulatory Information page.

3. Customer due diligence

Before establishing or continuing a relationship, we may verify full legal name, date and place of birth, nationality, residential address, tax residence, contact information, government identification, employment or business activity, expected account activity, purpose of the relationship, source of funds, source of wealth, and payment-method ownership. Verification may be performed directly or through an approved external provider.

4. Individual documents

Individuals may be asked to provide:

• Passport or national identity card;
• Proof of residential address;
• Selfie or live identity check;
• Tax information;
• Bank statement;
• Employment information;
• Source-of-funds evidence;
• Source-of-wealth evidence; or
• Additional supporting documents.

Documents must be valid, clear, complete, and authentic. Expired, altered, incomplete, or inconsistent documents may be rejected.

5. Corporate and institutional clients

Companies, funds, partnerships, trusts, foundations, and other legal arrangements may be required to provide a certificate of incorporation or registration, constitutional documents, registered-office information, business address, company register extract, ownership structure, director and officer information, authorised signatory evidence, regulatory licences, financial statements, business model, bank-account evidence, source-of-funds and source-of-wealth information, purpose and expected activity, and information about beneficial owners and controlling persons.

We may independently verify information through official registers, databases, or professional advisers.

6. Beneficial ownership

We must understand who ultimately owns or controls a company, account, fund, trust, or legal arrangement. Beneficial owners and controlling persons may be required to complete identity and verification checks. Nominee arrangements, layered ownership, trusts, holding companies, or complex structures may require additional explanation and documentation. Failure to disclose the true beneficial owner may result in rejection, suspension, or termination.

7. Politically exposed persons

A politically exposed person is someone who holds or has held a prominent public function, together with certain family members and close associates. Being identified as a politically exposed person does not automatically prevent onboarding. However, enhanced due diligence, senior approval, additional source-of-wealth checks, and ongoing monitoring may be required.

8. Sanctions screening

We may screen clients, representatives, beneficial owners, counterparties, transactions, wallet addresses, and connected parties against applicable sanctions and watchlists. We will not knowingly provide services to a person or entity where doing so would breach applicable sanctions. Accounts or transactions may be restricted, frozen, rejected, returned, or reported where legally required.

9. Source of funds and source of wealth

We may request evidence showing how a particular payment was obtained; how trading or investment capital was accumulated; the nature of business income; employment income; investment proceeds; property sale proceeds; inheritance; dividends; financing; or another legitimate source.

Examples of supporting evidence may include bank statements, contracts, payslips, audited accounts, tax returns, sale agreements, dividend records, or legal documents. Providing a bank statement does not automatically complete a source-of-funds review.

10. Enhanced due diligence

Additional checks may be required where a relationship presents higher risk. Relevant factors may include high-risk jurisdictions, complex ownership, politically exposed persons, unusually large transactions, digital assets, adverse media, cash-intensive businesses, inconsistent information, sanctions exposure, unclear wealth, unusual payment patterns, or activity inconsistent with the stated account purpose. Enhanced checks may continue throughout the relationship.

11. Ongoing monitoring

KYC is not a one-time process. We may periodically request updated documents or information, and monitor whether activity is consistent with the known client profile, expected transaction volume, business purpose, source of funds, geographic exposure, account history, and stated trading or investment objectives. Failure to provide updated information may result in restrictions.

12. Transaction monitoring

Transactions may be reviewed automatically or manually. A transaction may be delayed or investigated where it appears unusual, inconsistent, structured to avoid controls, connected to a sanctioned party, linked to fraud, funded by an unrelated third party, associated with a high-risk wallet, inconsistent with the client profile, or otherwise potentially unlawful. We are not required to process a transaction merely because it has been requested.

13. Digital asset checks

Digital asset deposits and withdrawals may be subject to blockchain analytics and wallet screening. We may reject or investigate transactions involving stolen assets, sanctioned wallets, darknet markets, mixers or tumblers, ransomware, fraud, unlawful gambling, terrorist financing, scams, unlicensed services, or other high-risk exposure. Clients must use supported networks and wallets that they are authorised to control.

14. Third-party payments

Payments should ordinarily come from and be returned to an account, card, wallet, or payment method held in the verified client's name. Third-party funding may be rejected unless expressly approved and fully verified.

15. Suspicious activity reporting

Where required, Roca VC Limited may submit reports or provide information to a financial intelligence unit, regulator, law-enforcement agency, court, bank, or other competent authority. We may be legally prohibited from telling a client that a report has been made or an investigation is taking place.

16. Record retention

KYC, transaction, communication, and investigation records may be retained for the minimum period required by applicable law and for longer where permitted for litigation, investigation, fraud prevention, or regulatory purposes. Records will be handled in accordance with the Privacy Policy.

17. Refusal, restriction, and termination

Roca VC Limited may refuse, suspend, limit, or terminate a relationship where verification cannot be completed; information is false or misleading; documents are not provided; source of funds cannot be established; sanctions concerns arise; fraud or criminal conduct is suspected; the relationship exceeds risk tolerance; a service provider requires the restriction; or law or regulation requires action. We may not be able to disclose the full reason for a decision.

18. Client responsibilities

Clients must provide accurate information; disclose beneficial ownership; use payment methods they are authorised to control; respond promptly to information requests; notify us about relevant changes; avoid using the service for unlawful activity; and provide reasonable evidence supporting transactions. Submitting false documentation may be reported to the relevant authorities.

Contact

Compliance enquiries may be sent to:

Roca VC Limited Compliance email: compliance@rocavc.com Telephone (UK): +44 7474 625779 Registered office: England, United Kingdom Company number: pending confirmation