AML / CFT Policy

VECTORLENS Sp. z o.o. applies a zero-tolerance approach to money laundering, terrorism financing and sanctions evasion. We cooperate fully with the General Inspector of Financial Information (GIIF) and other competent authorities.

Before entering into a business relationship, we identify and verify our clients:

• For companies: name, legal form, registered address, KRS/CEIDG or equivalent register number, NIP, and the identity of persons acting on the company's behalf.
• For individuals: full name, address and identity document data where required.
• For higher-value engagements: identification of the beneficial owner (UBO) holding more than 25% of shares or voting rights.

Each client relationship is assigned a risk level based on the client's jurisdiction, business profile, ownership structure and the nature of the ordered services. Higher-risk relationships — including clients from high-risk third countries, complex ownership structures or politically exposed persons (PEPs) — are subject to enhanced due diligence.

Clients and beneficial owners are screened against EU, UN and OFAC sanctions lists and PEP databases at the start of the relationship and periodically thereafter. We do not enter into relationships with sanctioned persons or entities.

We accept payments only by bank transfer to our corporate account from an account held in the client's own name. We do not accept cash, cryptocurrencies or third-party payments. Unusual payment patterns are reviewed before funds are accepted or returned.

Transactions are monitored for unusual or suspicious patterns. Where circumstances indicate a possible connection to money laundering or terrorism financing, we file a report with the GIIF and, where required, suspend the transaction. Tipping-off a client about a filed report is prohibited by law.

Identification data, due-diligence documentation and transaction records are retained for 5 years after the end of the business relationship, in accordance with the AML Act, and are then securely deleted.

Team members involved in client onboarding receive AML training and are required to escalate any red flags to the management board member responsible for AML compliance. This policy is reviewed at least once a year.

AML-related questions and verification requests: info@syntr0p1c.com.