A proportionate framework
IO Limited’s holding-company role calls for scrutiny of counterparties, transaction purpose and funding arrangements. This standard is not a claim that the group is a licensed financial institution or that every group business has identical statutory AML obligations.
The applicable duties must be established for the entity and activity involved. The responsible team should obtain qualified advice when the position is unclear.
Before a commitment
Read this standard together with counterparty verification and sanctions and trade controls.
- Establish the commercial purpose and whether the proposed structure fits that purpose.
- Check who will contract, pay and receive funds; investigate unexplained third-party arrangements.
- Request proportionate evidence of the origin of funds where risk warrants it.
- Record approval conditions and unresolved questions before execution.
When the facts do not fit
Examples requiring closer review include unexplained ownership layers, inconsistent documentation, pressure to bypass checks, payments split without a credible reason, or requests to refund money to an unrelated account.
These indicators are context for a review, not proof of a criminal offence. Consider the full information available and allow legitimate discrepancies to be explained.
Escalation and reporting
Pause the proposed action where a material concern remains unresolved and refer it to the person responsible for the corporate engagement. Keep the underlying facts and decision record restricted.
Whether a disclosure to an authority is required depends on the applicable law and facts. Seek appropriate legal advice, preserve relevant records and observe any restrictions on notifying the subject of a review. This website does not accept suspicious-transaction reports on behalf of a regulator.
Accountability
The relationship owner remains responsible for the decision and any follow-up. Reviews should leave a usable record of the evidence, reasoning and authorisation rather than a checked box.
Raise a concern about a direct IO Limited relationship through the business-conduct route. Include facts you can support and avoid sending unrelated personal or financial records.