Anti-money laundering & sanctions

1. Our position

Alin Li OÜ is a training and IT services company, not a financial institution. Because we work with clients across borders, we apply a proportionate, risk-based approach to two risks: dealing with sanctioned persons or entities, and being misused to move illicit funds. Sanctions obligations apply to us whatever our status under anti-money-laundering law.

2. Knowing our clients

Before we begin work, we identify our clients. For organisations, this includes their legal name, registration details, country and address, and who ultimately owns or controls them. We also make sure the engagement makes clear commercial sense. The depth of these checks depends on the level of risk: a known school, public body or established company in a low-risk country needs only basic checks, while complex ownership structures, higher-risk countries or unusual payments call for enhanced checks, or for us to decline the work.

3. Sanctions screening

We screen new clients, and the beneficial owners of company clients, against the United Nations Security Council and European Union consolidated sanctions lists, and other lists that apply where we operate. We re-screen periodically and whenever circumstances change.

We do not do business with sanctioned parties. If a match is found, we do not accept payment or deliver services.

4. Payments

We expect payments to come from the client’s own account, in the agreed amount and currency. Unusual payment arrangements are paused and verified before we accept money or deliver a service, and we may ask for additional information.

5. Reporting and records

Anyone at Alin Li who handles client onboarding or payments knows the warning signs and how to raise a concern. Suspicious activity is escalated internally and, where appropriate, reported to the relevant Financial Intelligence Unit. We keep client identification, screening results, contracts and invoices for the period required by law.

Compliance questions: Compliance@alinli.com.