Anti-Money Laundering Policy 


We are fully committed to preventing money laundering and complying with legal requirements. This Anti-Money Laundering Policy outlines our commitment to safeguarding against illicit financial activities. 

Customer Due Diligence 


  1. Identity and Verification measures: 
  • Identify customers and verify their identity. 
  • Obtain and verify customer details: 
  • Name 
  • Photograph (from an official document confirming their identity) 
  • Residential address 
  • Date of birth 
  • Sources of customer information include government-issued documents (e.g., passports), utility bills, bank statements, and credit reference agencies. 

     2. Customer Due Diligence Measures: 

  • For establishing a business relationship with a customer. 
  • For suspecting money laundering or terrorist financing. 
  • When there are doubts about a customer’s identification. 
  • For existing customers if their circumstances change. 

Internal Controls and Monitoring 

  • Internal controls and monitoring systems based on business size and complexity. 
  • High-value dealers will have additional obligations. 

Record Keeping 

  • Maintain records related to customer due diligence, transactions, and risk assessments. 


  • Regularly review and update the policy to ensure compliance with Money Laundering Regulations for each of the markets that we operate within. 


Updated 31 March 2023 

Nav Bahl 
Managing Director 

Rothian Ltd 

Anti-Money Laundering Policy 

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