Draft for legal and operational approval. Prepared in the name of Valor Financial (Mauritius) Ltd. It is not in force and does not activate accounts, services or promotions. The specific conditions and controls described must be validated before publication and contracting.
Trade America is the trading name of Valor Financial (Mauritius) Ltd.
- Mauritius registration
- C121829
- FSC licence · Asset management
- C113012533
- Head office address
- 5th Floor, The CORE Building, No.62, ICT Avenue, Cybercity, Ebene, Mauritius
In this document 8 sections
01 Purpose and framework
In this draft, Valor Financial (Mauritius) Ltd sets principles for preventing money laundering, terrorist financing and proliferation financing (AML/CFT/CPF). The programme must conform to FIAMLA, applicable Mauritius regulations, relevant sanctions and FSC guidance. This public version does not replace the internal manual, appointment of responsible officers or implementation of controls.
02 Risk-based assessment
The Company must assess risks arising from clients, beneficial owners, products, channels, locations, partners and transactions before and during the relationship. Classification requires documented reasons and review following material changes. Simplified procedures may be used only where legally permitted and justified; they do not remove identification requirements and are not a response to suspicion. Higher risk requires additional due diligence and approval.
03 Customer due diligence
The KYC/KYB policy covers identification of clients, representatives and beneficial owners, the relationship’s purpose and proportionate source-of-funds information. Anonymous or fictitious-name accounts must not be maintained. Missing required information can prevent starting or continuing a service and require compliance assessment. Commercial acceptance cannot waive mandatory checks.
04 Sanctions and politically exposed persons
Clients, representatives, owners and relevant counterparties must be checked against applicable sanctions lists and assessed for political exposure and other risks. Name matches require analysis to avoid false positives. Politically exposed status is not evidence of wrongdoing; it requires the corresponding legal treatment, including enhanced diligence, source of wealth and funds, and competent approval where required. Blocking or freezing measures require their own legal basis and procedure.
05 Monitoring and reporting suspicion
The Company must monitor whether activity is consistent with the declared profile and purpose, investigate anomalies and document decisions. Suspicion must be escalated to the MLRO or deputy without improper commercial interference for assessment and reporting where required. Statutory confidentiality duties may prevent disclosure to the client of a suspicious-report filing or its contents. This does not remove the duty to treat clients respectfully and preserve their rights.
06 Payments, refusal and restrictions
Payments require traceability, ownership and justification consistent with the service. Unexplained sources, inconsistent documents or unacceptable risk can lead to refusal, proportionate suspension or closure following assessment and law. AML checks do not authorise appropriation of funds, invented “unlocking fees” or unjustified retention. Refunds and legal orders must follow payment controls and compliance direction.
07 Record retention and protection
Due-diligence, account and correspondence records covered by Mauritius AML rules must be kept for at least seven years after the relationship ends; transaction records for seven years after completion. Suspicious-report records have their own statutory period of at least seven years from reporting. A preservation order may require longer retention. The Company must enable reconstruction of transactions, restrict access and delete data when legal necessity ends, consistently with the privacy policy.
08 Governance and review
Management must approve the programme and provide resources, responsible officers, training and risk-proportionate independent review. The internal manual must define escalation, evidence, continuity, list updates and supplier assessment. Audits, tests and operational records are needed to demonstrate compliance; publication alone does not prove that controls work. Clients may request clarification through the stated channel, subject to statutory confidentiality restrictions.
Official references
Sources consulted for this version. Check current texts and procedures before applying them.
Company contact
Valor Financial (Mauritius) Ltd
Trading name: Trade America