Terms & Conditions

1. Introduction

MURLAN LIMITADA (the "Company") is committed to preventing money laundering and terrorist financing. This Anti-Money Laundering (AML) policy outlines our procedures and controls to detect and prevent the use of our services for illicit purposes in accordance with Costa Rican law and international standards.

2. Customer Due Diligence (CDD)

We conduct appropriate customer due diligence measures before establishing business relationships. This includes verifying customer identity, understanding the nature and purpose of the business relationship, and conducting ongoing monitoring of transactions.

3. Know Your Customer (KYC)

All users are required to complete our KYC verification process, which includes providing valid identification documents and proof of address. We reserve the right to request additional documentation to verify your identity and source of funds or source of wealth where necessary.

4. Sanctions Screening

The Company maintains a zero-tolerance policy regarding transactions involving sanctioned individuals, entities, or jurisdictions. All customers and related parties are screened against global sanctions lists, specifically covering the following jurisdictions and bodies:

• United Nations (UN): The UN Security Council Consolidated List.
• European Union (EU): The Consolidated List of financial sanctions.
• United Kingdom (UK): The HM Treasury/OFSI Consolidated List.
• United States (OFAC): The Specially Designated Nationals (SDN) and Blocked Persons List.
• Australia: The DFAT Consolidated List.

Any match found during screening will result in the immediate rejection of the business relationship or the freezing of the transaction.

5. Transaction Monitoring

We monitor all transactions for suspicious activity, including unusual patterns, large transactions, and rapid movement of funds. Our automated systems and compliance team work together to identify and investigate potentially suspicious transactions.

6. Suspicious Activity Reporting

If we detect or suspect money laundering or terrorist financing activity, we are obligated to report this to the relevant authorities without notifying the customer. We maintain detailed records of all suspicious activity reports filed.

7. Prohibited Activities

Users are strictly prohibited from using our services for money laundering, terrorist financing, fraud, or any other illegal activities. We reserve the right to freeze accounts, confiscate funds, and report users to law enforcement if illegal activity is suspected.

8. Record Keeping

We maintain comprehensive records of all customer identification data, transaction history, and communications for a minimum of five years as required by law. These records may be provided to law enforcement and regulatory authorities upon request.

9. Training and Compliance

Our staff receives regular training on AML policies and procedures. We continuously review and update our AML program to ensure compliance with evolving regulations and best practices in the industry.

10. Cooperation with Authorities

We fully cooperate with law enforcement agencies and regulatory bodies in their investigations of money laundering and terrorist financing. We respond promptly to all lawful requests for information and documentation.