Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

1. Purpose of This Policy

Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements exist to protect the integrity of the financial system and to prevent the misuse of professional services for unlawful purposes.

As an accounting and advisory firm operating under Bulgarian law, Aidos Accountancy Services Ltd. (“Aidos”) is legally required to apply AML and KYC measures. This public policy explains, in clear and practical terms, how these obligations affect our clients and our working relationship.

The purpose of publishing this policy is transparency: to set expectations, reduce uncertainty, and ensure that AML/KYC requirements are understood as a standard part of professional cooperation, not as an exceptional or discretionary measure.

2. Legal and Regulatory Framework

Aidos operates within the European Union and Bulgaria and is subject to applicable AML legislation, including:

The EU Anti-Money Laundering Directives (AMLD), as implemented into national law
The Bulgarian Measures Against Money Laundering Act
Related secondary legislation and guidance issued by competent authorities

These laws impose obligations on certain professional service providers, including accounting and advisory firms, to identify clients, understand business activities, and remain alert to potential risks of misuse.

3. Aidos as an Obliged Entity

Under Bulgarian and EU law, Aidos qualifies as an “obliged entity” for AML purposes.

This means that Aidos is legally required to:

Identify and verify clients and relevant controlling persons
Understand the nature and purpose of the business relationship
Apply appropriate due diligence measures
Maintain records as required by law
Comply with statutory reporting obligations where applicable

These obligations apply irrespective of client size, nationality, or sector.

4. Our Risk-Based Approach

AML legislation requires a risk-based approach. In practice, this means that AML/KYC measures are applied proportionately, taking into account the nature of the client, the services provided, and the context of the engagement.

Most clients experience standard and straightforward verification procedures. In some cases, additional information may be required to meet legal obligations. This does not imply suspicion or wrongdoing; it reflects the need to apply AML requirements consistently and in line with the law.

5. Client Identification & Verification (KYC)

As part of onboarding and, where relevant, during an ongoing engagement, Aidos may request information and documentation such as:

Identification details of individuals (e.g. directors, shareholders, ultimate beneficial owners)
Company registration and constitutional documents
Ownership and control structure information
Information about business activities and source of funds
Confirmation of tax residence or operational substance

The scope and timing of these requests depend on the services provided and applicable legal requirements. Documentation may be requested before services commence or during the course of an engagement.

6. Enhanced Due Diligence (When Applicable)

In certain situations, legislation requires enhanced due diligence. This may involve requesting additional information or documentation to better understand the client or the intended services.

Enhanced due diligence is a legal requirement in specific circumstances and does not in itself indicate any assumption about a client’s conduct or integrity.

7. Ongoing Monitoring

AML and KYC obligations are not a one-time formality. Where required by law, Aidos must maintain an ongoing understanding of the business relationship.

This may involve:

Periodic updates of client information
Requests for clarification following changes in ownership, activity, or structure
Review of information already provided

Clients are expected to inform Aidos of material changes relevant to their engagement.

8. Client Responsibilities

Clients are expected to:

Provide accurate, complete, and up-to-date information
Provide clear and legible copies of requested documents
Respond to AML/KYC requests in a timely manner
Inform Aidos of relevant changes affecting ownership, management, or activities
Cooperate with legal and regulatory requirements applicable to the engagement

Failure to provide required information may affect Aidos’ ability to continue providing services.

9. Refusal or Termination of Services

Aidos is legally obliged to refuse to establish, or to terminate, a business relationship where AML/KYC requirements cannot be met.

Such decisions are driven by statutory obligations and are not discretionary. In these cases, Aidos is not permitted to provide further services related to the engagement.

10. Confidentiality & Data Protection

All AML/KYC information is handled in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).

Client data is processed lawfully, securely, and only for legitimate purposes. Further details are set out in Aidos’ Privacy Policy and GDPR Statement, which form part of Aidos’ broader governance framework.

AML/KYC records are retained for the legally required period, generally five years, in accordance with applicable legislation.

11. Reporting Obligations

Where required by law, Aidos must comply with statutory reporting obligations to competent authorities.

These obligations are strictly regulated and subject to legal confidentiality rules. Aidos cannot disclose details of such matters to clients where the law prohibits it.

12. Contact & Queries

Questions regarding this policy or general AML/KYC requirements may be directed to:

[email protected]

For verification procedures related to a specific client engagement, clients should contact their designated Aidos account manager.

13. Key Definitions (For Clarity)

Ultimate Beneficial Owner (UBO)
The natural person or persons who ultimately own or control a client, whether directly or indirectly, or on whose behalf a transaction or activity is conducted.

Enhanced Due Diligence (EDD)
Additional verification measures required by law in certain situations, applied to meet regulatory obligations.

14. Changes to This Policy

This policy may be updated to reflect changes in legislation, regulation, or professional practice.

This policy forms part of Aidos’ Governance Framework.

Last reviewed and updated: January 2026