Client identification (KYC) and anti-money laundering (AML) policy
Four verification stages, documents accepted by country, real timelines and the explanation of why the matching-payer rule exists.
Sening Capital is required to identify every client before granting access to trading. Verification requires a document evidencing identity and a proof of address, and in certain cases evidence of the source of funds. Review takes up to 24 hours on business days. These requirements derive from the licence and from the FATF recommendations, and cannot be waived at the client's request.
1. Documents accepted by country
| Country | Identity document | Proof of address |
|---|---|---|
| Mexico | INE/IFE, passport or photographic driving licence | Electricity, water or gas bill; bank statement; telephone bill |
| Colombia | Cédula de ciudadanía or passport | Utility bill; bank statement; certificate of residence |
| Peru | DNI or passport | Utility bill; bank statement; tenancy agreement |
| Chile | Cédula de identidad or passport | Utility bill; bank statement; certificate of address |
| Argentina | DNI or passport | Utility bill; bank statement; tenancy agreement |
| Brazil | RG, CNH or passport | Electricity, water or telephone bill; bank statement; tenancy agreement |
| Ecuador and Panama | Cédula de identidad or passport | Utility bill; bank statement |
Maximum age of the proof of address: 3 months. For card-format documents both sides are required.
2. Purpose of the policy
This policy sets out the procedures for client identification, risk assessment, transaction monitoring and reporting of suspicious activity, with the aim of preventing the laundering of the proceeds of criminal activity and the financing of terrorism.
3. Regulatory framework
The policy is based on the Anti-Money Laundering and Countering the Financing of Terrorism legislation of the jurisdiction of the licence, on the FATF recommendations and on the requirements of the FCA.
4. Identification procedure
Stage 1 — Evidence of identity
We accept: a national identity document (INE/IFE in Mexico, cédula de ciudadanía in Colombia, DNI in Peru and Argentina, RG or CNH in Brazil, cédula de identidad in Chile), a passport or a photographic driving licence.
Document requirements: not expired; all four corners visible in the image; legible text; a distinguishable photograph; and, for card-format documents, both sides.
Stage 2 — Evidence of address
We accept documents no more than 3 months old: a utility bill (electricity, water, gas), a bank statement, a telephone or internet bill, a certificate from a public body or a tenancy agreement.
Requirements: full name matching the profile; complete address; issue date visible; and it must not be a screenshot from a mobile application lacking the issuing institution's identifying details.
Stage 3 — Evidence of the payment instrument
For cards: a photograph with the middle digits of the number hidden and the CVV covered, leaving the first six and last four digits and the holder's name visible.
Stage 4 — Source of funds
Requested when cumulative deposits exceed 10,000 USD, in the event of atypical activity, or when the client is classified in the high-risk category. We accept: an income certificate, a tax return, a contract for the sale of assets, inheritance documentation or a statement from the sale of securities.
5. Timelines
Standard review takes up to 24 hours on business days. If additional documentation is requested, the timeline extends to 5 business days.
6. Risk categories
Clients are classified by risk level according to country of residence, the nature of their activity, trading volume and personal status. Politically exposed persons (PEPs), their family members and close associates are treated as high risk, as are clients from jurisdictions identified by the FATF as having deficiencies in their prevention systems. Enhanced due diligence (EDD) is applied to these clients, and opening an account requires approval from the compliance officer.
7. Transaction monitoring
An automated system watches for: a mismatch between trading volume and the declared profile; minimal-risk trading accompanied by high volumes (an indication of funds circulation); frequent deposits and withdrawals without trading activity; attempts to use third-party payment instruments; and transactions linked to high-risk jurisdictions.
8. Matching-payer rule
Deposits are accepted only from instruments issued in the account holder's name. Withdrawals are made by the same method and to the same details. Third-party payments are rejected and returned to the sender, less the actual cost of the transfer.
9. Refusal and suspension
The Company may refuse to open an account, suspend trading or close an account without a detailed explanation of the reasons where anti-money laundering rules require it. Where there are indications of unlawful activity, the Company is obliged to report it to the competent body and is legally prevented from informing the client of that report.
10. Sanctions screening
All clients are screened against the lists of the United Nations, OFAC, the European Union, the United Kingdom and the applicable national lists, both at registration and periodically thereafter.
11. Record retention
Identification documents and transaction records are retained for a minimum of 5 years from the end of the client relationship.
12. Staff training
Employees who interact with clients and those who process transactions receive anti-money laundering training at least annually.
13. Designated officer
Anti-money laundering compliance is handled by the company’s compliance department. Contact: [email protected].
Entity details
Sening Capital Ltd — registered office 12 John Princes Street, London, Westminster, W1G 0JR, United Kingdom, company registration number 11237561, licence FCA 806721.
All correspondence — legal matters, data protection, compliance and complaints — goes to the single address [email protected]. State the matter in the subject line so that the message reaches the right department.
In the event of any discrepancy between translated versions of this document, the English version prevails.
Frequently asked questions
Client identification is an obligation arising from the licence and from anti-money laundering legislation. Without a verified identity, the broker cannot grant access to trading or process withdrawals. The requirement applies to every client without exception.
To evidence identity we accept the INE/IFE card, a passport or a photographic driving licence. To evidence the address we accept a utility bill, a bank statement or a telephone bill no more than 3 months old, showing the client's full name and address.
Standard review takes up to 24 hours on business days. If additional documentation is required — for example, evidence of the source of funds — the timeline extends to 5 business days. The verification status is shown in the personal area.
No. Deposits are accepted only from payment instruments issued in the account holder's name. Third-party payments are rejected and returned to the sender, less the actual cost of the transfer. The rule derives from anti-money laundering requirements.
It is requested when cumulative deposits exceed 10,000 USD, when atypical activity is detected, or when the client is classified in the high-risk category. We accept income certificates, tax returns, contracts for the sale of assets, inheritance documentation or statements from the sale of securities.
Yes, where anti-money laundering rules require it. The company may refuse to open an account, suspend trading or close an account without detailing the reasons if those rules impose this. Where there are indications of unlawful activity, the company is obliged to inform the competent authority and is legally prevented from telling the client.