Introduction

CannyCask Limited is committed to preventing money laundering, terrorist financing, fraud and other forms of financial crime.

This AML / KYC Notice explains the customer verification and compliance measures that may apply when using the CannyCask platform and services.

Scope

This policy applies to all customers, partners and counterparties interacting with CannyCask, regardless of location or transaction size.

Compliance requirements may vary depending on the nature of the customer, transaction and jurisdiction involved.

Customer Verification

Before completing certain transactions, customers may be required to complete identity verification procedures.

These may include:

1. proof of identity;
2. proof of address;
3. date of birth verification;
4. beneficial ownership verification;
5. company verification for business customers; and
6. other information reasonably required to satisfy compliance obligations.

Know Your Customer (KYC)

Individual customers may be required to complete Know Your Customer (KYC) checks before acquiring ownership of a cask.

KYC requirements help verify identity and support compliance with applicable legal and regulatory obligations.

Know Your Business (KYB)

Corporate, partnership, trust and institutional customers may be required to complete Know Your Business (KYB) verification.

This may include verification of:

1. legal entity status;
2. directors;
3. authorised representatives;
4. beneficial owners; and
5. corporate documentation.

Enhanced Due Diligence

Where required, CannyCask may perform Enhanced Due Diligence (EDD).

EDD may be applied where transactions, customers or jurisdictions present elevated compliance risk.

Additional information or documentation may be requested before a transaction can proceed.

Source of Funds & Source of Wealth

Where appropriate, customers may be required to provide information regarding the source of funds or source of wealth associated with a transaction.

Failure to provide requested information may result in delays, suspension or cancellation of a transaction.

Sanctions & Financial Crime Screening

CannyCask may conduct sanctions, politically exposed person (PEP), adverse media and other financial crime screening checks.

Transactions may be delayed, restricted or declined where compliance concerns are identified.

Ongoing Monitoring

CannyCask reserves the right to conduct ongoing monitoring of customer relationships and transactions.

Additional verification may be requested during the course of a customer relationship.

Record Keeping

CannyCask maintains records of compliance activities in accordance with applicable legal and regulatory requirements.

Access to compliance records is restricted to authorised personnel and service providers with a legitimate need to access such information.

Refusal or Termination of Services

CannyCask reserves the right to:

1. refuse a transaction;
2. suspend a transaction;
3. request additional information;
4. terminate a customer relationship; or
5. report suspicious activity to relevant authorities,

where required by law, regulation or internal compliance policies.

Contact

For compliance-related enquiries, please contact:

support@cannycask.com

Governing Law

This AML / KYC Notice shall be governed by the laws of Scotland.

Any dispute arising from this notice shall be subject to the exclusive jurisdiction of the Scottish courts.