DC-Services UK AML Policy

Detection of Suspicious Activity

DC-SERVICES employs specific internal controls to detect and flag any indicators of suspicious activity within the data sets we analyse. Our staff are trained to recognise anomalies that may suggest money laundering, such as inconsistent asset histories or attempts to obfuscate ownership through fragmented digital records. In the event that suspicious activity is identified, our Money Laundering Reporting Officer (MLRO) is empowered to take immediate action, including the suspension of services and, where legally mandated, the submission of reports to the relevant authorities.

• ›Written intake brief signed by the client
• ›Conflicts screen and independence check
• ›Defined deliverable list and retention envelope

Governance and Supervisory Controls

The governance of our AML policy is overseen by our senior management team, who ensure that the firm's risk appetite remains low and that compliance is prioritised over commercial gain. We maintain a clear hierarchy of responsibility, with the MLRO reporting directly to the Board of Directors. This structural independence ensures that AML considerations are never compromised. Our supervisory QA processes audit a random selection of files each quarter to confirm that due diligence has been performed to the standards set out in our operational handbook.

• ›Source hashing at intake
• ›Role-based, time-bound access
• ›Two-stage review before release

Operational Boundaries and Non-Custody

To prevent any misunderstanding of our AML role, it is critical to state that DC-SERVICES is not a financial institution, bank, or asset custodian. We do not hold client money, we do not execute trades, and we do not provide payment services. Our AML policy is therefore focused on the integrity of information and the prevention of facilitating financial crime through documentation. We do not provide advice on how to structure assets, and we explicitly refuse any engagements that appear to involve the integration or layering of illicit funds into the legitimate economy.

Implementation and Compliance Contact

Effective implementation of this AML policy requires transparency and cooperation from all parties involved. Institutional clients are expected to provide timely and accurate information during the onboarding process. Failure to meet our due diligence requirements will result in the immediate termination of the engagement. For further details on our AML protocols or to request a copy of our full compliance manual for institutional assessment, please contact our compliance department. We remain committed to fostering a secure and transparent digital-asset environment through rigorous documentary standards.