Anti-Money Laundering & Counter-Terrorist Financing Policy

1.1This anti-money-laundering and counter-terrorist-financing policy is issued by STARECOM ("we", "us"), the operator of starecom.net and the provider of the services described on it.

1.2We are committed to preventing our services from being used to launder money, finance terrorism, evade sanctions, or disguise the proceeds of crime. This policy sets out the controls we apply to every client relationship.

1.3The framework follows the risk-based approach of the EU Anti-Money Laundering Directives and the FATF Recommendations, applied proportionately to a professional services business of our size. Where the operator's home jurisdiction imposes stricter obligations, those apply.

1.4This policy is reviewed at least annually and whenever there is a material change in law, in our services, or in our client base.

2.1We assess each prospective client and engagement for money-laundering and terrorist-financing risk before accepting the work, and keep that assessment under review for the life of the relationship.

2.2Factors that raise the risk rating include: an ownership structure that is opaque or unusually complex; a client, owner or counterparty connected to a high-risk or sanctioned jurisdiction; a request to receive payment from, or make payment to, a party that is not the client; unusual urgency combined with reluctance to provide documentation; a proposed use case that sits close to a category in the Acceptable Use & Prohibited Activities policy; and payment arrangements that make no commercial sense for the work.

2.3Higher-risk relationships receive enhanced due diligence — additional documentation, verification of source of funds, and sign-off by the responsible person named in clause 8 — or are declined.

2.4We may decline any engagement, at any stage, without giving reasons, where we are not satisfied that the risk is acceptable.

3.1We identify and verify every client before the engagement begins, and in any event before we accept payment.

3.2Business clients. We collect and verify: the registered legal name, legal form and registration number; the registered address; evidence of registration from the relevant company register; the identity of the individuals we deal with and their authority to bind the company; and the identity of any beneficial owner holding 25% or more of the shares or voting rights, or otherwise exercising control.

3.3Individuals. Where the client is an individual, or where an engagement exceeds the equivalent of EUR 15,000 in aggregate, we collect a government-issued photographic identity document and evidence of residential address dated within the last three months.

3.4Ongoing monitoring. We keep the information current for the life of the relationship, refresh it on a risk-sensitive basis, and check that the transactions we see remain consistent with what we know about the client and its business.

3.5Where we cannot complete due diligence, we do not proceed: we do not start work, we do not accept funds, and we return any funds already received to their source.

4.1Before onboarding, and periodically thereafter, we screen the client, its directors and its beneficial owners against the consolidated sanctions lists maintained by the European Union and the United Nations, and against the lists applicable in the operator's home jurisdiction.

4.2We also screen for politically exposed persons (PEPs), their family members and known close associates. A PEP relationship is not refused automatically, but it is treated as higher risk, requires enhanced due diligence including establishment of source of wealth and source of funds, and requires sign-off by the responsible person.

4.3A positive sanctions match stops the relationship immediately. We do not proceed, we do not return funds without instruction, and we report as required by law.

4.4We do not provide services to any person or entity subject to applicable sanctions, or established in a jurisdiction subject to comprehensive sanctions.

5.1These rules are absolute and are not negotiable on commercial grounds:

• We accept payment only from an account held in the client's own name. Payment from a parent, subsidiary or affiliate is accepted only where that entity is disclosed and verified in advance as part of the engagement.
• We do not accept third-party payments. If a payment arrives from a party we have not verified, it is returned to source and the engagement is paused pending explanation.
• We do not accept cash. In any amount, in any circumstances.
• We do not accept cryptocurrency or other virtual assets unless separately agreed in writing in advance, subject to enhanced due diligence on the source of the assets and on the wallet's provenance.
• We do not make refunds to a different card, account or person from the one that paid. This is why the Refund & Cancellation Policy returns funds to the original payment method only.
• We do not act as a conduit for funds. We do not receive money on a client's behalf to pass on to someone else, and we do not hold client money.

5.2Accepted currencies and payment methods are published in the Payment & Billing Disclosures.

6.1We do not act for shell companies with no discernible economic purpose, for clients who refuse to identify their beneficial owners, or for anyone who asks us to structure payments to avoid a reporting threshold.

6.2The categories of work we refuse outright are listed in the Acceptable Use & Prohibited Activities policy, which forms part of this framework. They include unlicensed financial services, investment schemes and guaranteed-return offerings, unlicensed gambling, and any deceptive or fraudulent operation.

6.3Where a client's business would require a licence or authorisation, we ask to see it before accepting the work, and we verify it with the regulator where a public register exists.

7.1Anyone in the business who sees something that does not make sense must escalate it to the responsible person named in clause 8 immediately. There is no threshold for escalation and no penalty for escalating something that turns out to be innocent.

7.2The responsible person assesses the concern, records the assessment in writing, and decides whether it must be reported.

7.3Where we know or suspect, or have reasonable grounds to suspect, that funds are the proceeds of crime or are connected to terrorist financing, we make a suspicious activity report to the competent Financial Intelligence Unit in the operator's jurisdiction, without delay and before carrying out the transaction where the law requires us to wait.

7.4Tipping off. We do not tell the client, or anyone else, that a report has been made or is being considered. Doing so is a criminal offence in most jurisdictions. If we decline or pause an engagement for this reason, we will simply decline it, and we are not able to explain why.

7.5We cooperate fully with lawful requests from law enforcement, financial intelligence units and regulators.

8.1The person responsible for this policy, for receiving internal escalations and for making reports is the operator's director. The director is named in the operator identity block on the Terms of Use and in the footer of every page once the entity is registered.

8.2Everyone involved in accepting clients or handling payments receives training on this policy on joining and at least annually thereafter, covering the risk indicators above, the escalation route, and the tipping-off prohibition.

8.3We retain due diligence records, transaction records and the reasoning behind any assessment for 5 years after the end of the client relationship, or longer where a specific legal obligation requires it. Retention is also described in the Privacy Policy.

8.4Questions about this policy go to .