Last Updated: December 9, 2025 | Access Global LLC trading as "Access Global"
1. Purpose of This Policy
This Anti-Money Laundering and Counter-Terrorist Financing Policy ("AML Policy") sets out the principles and controls adopted by Access Global LLC to mitigate the risk that the Company may be used, intentionally or unintentionally, to facilitate money laundering, terrorist financing, or other financial crime.
The Company operates under the trading name "Access Global." All references in this policy to the Company include activities conducted under that trading name.
This policy is designed to reflect the limited, non-regulated nature of the Company's activities and to support — but not replace — the AML obligations of independently regulated financial institutions.
2. Scope and Business Model
The Company operates exclusively as an institutional access and workflow coordination firm. The Company:
- does not provide regulated financial services;
- does not execute transactions;
- does not hold or control client funds or assets;
- does not open, approve, or maintain client accounts;
- does not perform AML, KYC, CDD, or EDD determinations;
- does not conduct transaction monitoring or file regulatory reports.
All regulated AML and CTF obligations remain the sole responsibility of independently regulated financial institutions.
3. Allocation of AML Responsibilities
3.1 Regulated Institutions
Where the Company introduces or coordinates access to a regulated financial institution: that institution acts as the regulated counterparty; that institution is solely responsible for AML/CTF compliance; all onboarding, verification, monitoring, and reporting obligations rest with that institution.
3.2 Role of the Company
The Company's AML-related responsibilities are limited to: avoiding facilitation of obvious financial crime risk; maintaining proportionate internal risk awareness controls; declining engagement where clear red flags are present; cooperating with regulated partners and authorities where legally required.
In limited cases, the Company may collect documentation solely upon the express instruction of a regulated institution and solely for transmission to that institution.
3.3 Financial Crime Risk Mitigation Prior to Introduction
As part of its commitment to preventing financial crime and supporting the AML and CTF obligations of regulated financial institutions, the Company applies limited, non-determinative financial crime risk-mitigation measures prior to introducing prospective counterparties.
Such pre-introduction risk-mitigation measures may include: collection of high-level identity or corporate information; a high-level understanding of the nature of the prospective counterparty's business or activity; basic name screening against publicly available sanctions or watchlists; consideration of jurisdictional or sectoral risk indicators; identification of material inconsistencies, unusual requests, or apparent red flags.
All formal AML, KYC, onboarding, and compliance determinations remain the sole responsibility of the regulated institution.
4. Risk-Based Approach
The Company applies a proportionate, risk-based approach aligned with international AML standards, including FATF principles, appropriate to its limited role. Risk considerations include counterparty profile, jurisdiction, sector, reputational risk, and consistency of information provided.
5. Prohibited Relationships
The Company will not knowingly engage with: sanctioned persons, entities, or jurisdictions; shell banks or unregulated intermediaries; parties attempting to circumvent AML controls; arrangements designed to obscure beneficial ownership or source of funds.
6. Sanctions Awareness
The Company maintains awareness of major international sanctions regimes, including UN, OFAC, UK, and EU lists, and will refuse engagement where a counterparty is clearly sanctioned.
7. Data Handling
Any documentation collected on behalf of regulated institutions is: collected only upon express instruction; transmitted securely; not verified or assessed by the Company; retained only for the minimum period necessary. Data handling is governed by the Company's Privacy Policy.
8. Suspicious Activity Awareness
The Company does not perform transaction monitoring or submit Suspicious Activity Reports. However, if Company personnel become aware of suspected financial crime, including during pre-introduction risk mitigation, the Company may: decline to proceed with an introduction; terminate engagement; escalate concerns to the relevant regulated institution; cooperate with lawful requests from competent authorities.
9. Recordkeeping
Appropriate internal records relating to counterparties, engagement decisions, and risk-based refusals are maintained for legitimate business and legal purposes only.
10. Governance
AML oversight is the responsibility of senior management. Given the Company's limited role, no dedicated MLRO is appointed.
11. Training
Relevant personnel receive guidance on financial crime red flags, escalation procedures, and the Company's limited AML role.
12. Review
This policy is reviewed periodically and updated as required.
13. Governing Law
This policy is governed by the laws of the State of Montana, United States.
© 2025 Access Global LLC. All rights reserved.
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