AML & KYC Policy
Last updated: 10 November 2026
1. Purpose
Mosaic Mindset Unipessoal LDA is committed to preventing money laundering and terrorist financing. This policy describes the measures we apply in line with Portuguese Law No. 83/2017, the EU Anti-Money Laundering Directives and applicable sanctions regimes.
2. Know Your Customer (KYC)
Before entering into a business relationship we identify and verify every client. For individuals: full name, date of birth, nationality, address and a valid identity document. For companies: registered name, registration number, registered address, a recent commercial register extract and the identity of legal representatives.
3. Beneficial ownership
We identify the ultimate beneficial owner(s) holding, directly or indirectly, more than 25% of shares or voting rights or otherwise exercising control, and verify them against the Central Register of Beneficial Ownership (RCBE) or equivalent registers.
4. Risk-based approach
Each client is assigned a risk level based on country, sector, structure and transaction profile. Enhanced due diligence applies to high-risk situations, including high-risk third countries, complex ownership structures and politically exposed persons (PEPs), and may include source-of-funds checks and senior management approval.
5. Sanctions & PEP screening
Clients and beneficial owners are screened against EU, UN and other applicable sanctions lists and PEP databases at onboarding and periodically thereafter. We do not work with sanctioned persons or entities.
6. Payments
We accept payments only by bank transfer from an account held in the client's own name at a regulated institution. We do not accept cash, cryptocurrency, or payments from or to third parties, and we do not refund to accounts other than the originating account.
7. Ongoing monitoring
We monitor business relationships for consistency with the client's profile and update KYC information periodically and whenever material changes occur.
8. Reporting
Suspicious transactions are reported to the Portuguese Financial Intelligence Unit (Unidade de Informação Financeira – UIF) and the Central Department of Criminal Investigation and Prosecution (DCIAP), as required by law. We may suspend or refuse any transaction without explanation where required.
9. Record keeping
Identification documents, verification records and transaction data are kept securely for 7 years after the end of the business relationship.
10. Refusal of service
We reserve the right to refuse or terminate a business relationship if a client fails to provide the required information or if risks cannot be adequately mitigated.
11. Training & responsibility
Our management is responsible for this policy, which is reviewed at least annually. Staff receive regular AML/CFT training. Compliance questions can be raised by phone at +351 938 875 183 or via the contact form.