Anti-Money Laundering and Counter-Terrorist Financing Policy

1. Purpose and commitment

CGPH Banque d’affaires conducts its business in a manner designed to keep the proceeds of crime and the financing of terrorism away from the transactions it advises on. This policy summarises the framework applied across CGPH SAS and describes what clients, investors and counterparties can expect from us. We publish it for information, and it reflects internal procedures that remain confidential.

2. Legal framework

Our framework rests on Directive (EU) 2015/849 as amended, on Title VI of Book V of the French Monetary and Financial Code, on the European Union regulations giving effect to international financial sanctions, and on the recommendations of the Financial Action Task Force. Where a group entity operates in another jurisdiction, the local requirements apply in addition to this framework, and the stricter standard prevails.

3. Governance

Senior management holds responsibility for the effectiveness of the framework. A designated compliance officer oversees its application, maintains the risk assessment, approves higher-risk relationships and acts as the point of contact for the competent authorities. The compliance function operates independently and has direct access to senior management. You may reach it at compliance@cgphbanquedaffaires.com.

4. Risk-based approach

We maintain a documented business-wide risk assessment covering client type, geography, product, transaction structure and delivery channel. Each relationship receives a risk rating, and that rating determines the depth of due diligence, the approval level required and the frequency of review.

5. Customer due diligence

Before entering into a business relationship we identify the client and verify that identity from reliable and independent sources. For a natural person this covers identity documents, address, date and place of birth, nationality and tax residence. For a legal entity this covers the certificate of incorporation, the articles of association, a register extract, the ownership and control structure, the identification of each beneficial owner holding more than twenty-five per cent and of the persons exercising control by other means, and evidence of the signing authority of the representative.

We establish the purpose and intended nature of the relationship, the source of funds and, where the risk profile calls for it, the source of wealth.

We apply enhanced due diligence, with senior approval, where the relationship involves a politically exposed person, a family member or close associate of one, a high-risk third country identified by the European Commission, a complex or unusually structured transaction, or any circumstance that our risk assessment classifies as elevated.

We keep this information current through periodic review, and we refresh it whenever a material change in the relationship comes to our attention.

6. Sanctions and screening

We screen clients, beneficial owners, representatives and counterparties against the sanctions lists maintained by the European Union, the United Nations, the French Treasury, the United States Office of Foreign Assets Control and the United Kingdom, together with politically exposed person and adverse media sources, at onboarding and on an ongoing basis. A confirmed match leads to the freezing of the relationship and to a report to the competent authority.

7. Monitoring and reporting

We monitor transactions and relationships for consistency with the profile we hold. Where a suspicion of money laundering or terrorist financing arises, our compliance officer files a declaration of suspicion with TRACFIN, the French financial intelligence unit, in accordance with Article L.561-15 of the French Monetary and Financial Code. The law prohibits disclosure of such a filing to the person concerned, and we train our staff accordingly.

8. Acceptance standards

We enter into relationships where the identity of the client and of every beneficial owner is established, where the source of funds is documented and coherent, and where the purpose of the transaction is clear and lawful. Relationships that fall outside these standards, including anonymous or fictitious-name accounts, shell arrangements without economic substance, cash settlement of professional fees above the legal threshold, and persons subject to applicable financial sanctions, remain outside our acceptance perimeter.

9. Record keeping

We retain identification documents, due diligence records and transaction documentation for five years from the end of the business relationship or from the execution of the transaction, in accordance with Article L.561-12 of the French Monetary and Financial Code, and we process those records as described in our Privacy Policy.

10. Training and internal control

Staff and relevant contractors receive anti-money laundering training on appointment and periodically thereafter, calibrated to their role. An internal control programme tests the application of these procedures, and its findings go to senior management for remediation.

11. Cooperation with authorities

We respond to lawful requests from TRACFIN, from judicial authorities and from other competent bodies within the timeframes they set, and we maintain the confidentiality that the law attaches to those exchanges.

12. Contact

Questions on this policy, and requests for us to complete an anti-money-laundering questionnaire, go to compliance@cgphbanquedaffaires.com.