Last Updated: June 22, 2026
1. Introduction
Fortress Fiduciary (“the Company”) is committed to preventing money laundering, terrorist financing, and other financial crimes. This AML Policy outlines the procedures we have implemented to ensure compliance with applicable laws and regulations in all jurisdictions where we operate.
2. Policy Statement
The Company maintains a risk‑based approach to anti‑money laundering and counter‑terrorist financing (AML/CTF). We will not knowingly facilitate, assist, or permit any transaction that involves proceeds of unlawful activities. All suspicious activities will be reported to the relevant authorities.
3. Customer Due Diligence (CDD)
Before establishing a business relationship or executing a transaction, we will:
- Identify and verify the customer’s identity using government‑issued documents (KYC).
- Identify and verify any beneficial owners of legal entities.
- Understand the purpose and intended nature of the business relationship.
- Conduct ongoing monitoring of accounts and transactions.
4. Enhanced Due Diligence (EDD)
For higher‑risk customers, including politically exposed persons (PEPs), customers from high‑risk jurisdictions, or complex/ unusually large transactions, we will apply enhanced due diligence measures, such as:
- Obtaining senior management approval for onboarding.
- Gathering additional documentation on source of funds and source of wealth.
- Increased frequency and depth of transaction monitoring.
5. Transaction Monitoring
We employ automated systems and manual reviews to monitor customer transactions for unusual patterns or suspicious activity. This includes:
- Large cash or wire transfers inconsistent with a customer’s profile.
- Structuring transactions to avoid reporting thresholds.
- Transactions with high‑risk countries or entities.
- Rapid movement of funds without apparent economic or lawful purpose.
6. Reporting of Suspicious Transactions
If we suspect or have reasonable grounds to suspect that funds are the proceeds of criminal activity, or that a transaction is related to terrorist financing, we will:
- File a Suspicious Activity Report (SAR) with the appropriate financial intelligence unit.
- Not disclose the reporting to the customer (“tipping off”).
- Freeze the funds if required by law or regulatory order.
7. Record Keeping
All customer identification documents, transaction records, and AML‑related reports will be retained for a minimum of 7 years after the business relationship ends, or as required by applicable law.
8. Training & Awareness
All employees, contractors, and agents receive regular AML training tailored to their roles. Training covers legal obligations, red‑flag indicators, and internal reporting procedures.
9. Compliance Officer
The Company has designated an AML Compliance Officer responsible for overseeing the implementation of this policy, conducting independent audits, and serving as the primary contact for regulatory authorities.
Contact: compliance@fortressfiduciary.com
10. Policy Review
This policy will be reviewed annually, or more frequently if required by regulatory changes or emerging risks, to ensure its continued effectiveness.
11. Contact Information
For questions regarding this AML Policy, please contact: