AML Policy (Anti-Money Laundering Policy) — Elevate Program

1. Purpose

The purpose of this policy is to prevent Pearce Courses Ltd (“the Company”) and its online platform (including the referral and payout system) from being used for money laundering, terrorist financing, or other forms of financial crime.
We comply with all applicable laws and regulations of the United Kingdom, including:

  • The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017) and subsequent amendments.
  • The Proceeds of Crime Act 2002.
  • UK Sanctions and Anti-Money Laundering Act 2018.

2. Scope

This policy applies to:

  • All users participating in our referral program or receiving payouts from the platform.
  • All transactions, withdrawals, and account-related activities conducted through our website.
  • The employees, partners, and contractors of Pearce Courses Ltd.

3. Regulatory Framework

We follow a risk-based approach to compliance, applying Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and ongoing monitoring where appropriate.
We cooperate with the National Crime Agency (NCA) and other relevant authorities when required.
The Company also complies with the requirements of the Office of Financial Sanctions Implementation (OFSI) regarding the enforcement of financial sanctions.

4. Restricted Countries

In order to comply with global sanctions, regulatory obligations, and our internal risk management policies, access to our services and the ability to initiate transfers or withdrawals are prohibited for residents of, or transactions involving, the following countries:

  • Afghanistan (AFG)
  • Belarus (BLR)
  • Central African Republic (CAF)
  • Cuba (CUB)
  • Democratic Republic of the Congo (COD)
  • Haiti (HTI)
  • Iran (IRN)
  • Iraq (IRQ)
  • Lebanon (LBN)
  • Libya (LBY)
  • Mali (MLI)
  • Moldova (MDA)
  • Myanmar (MMR)
  • North Korea (PRK)
  • Russian Federation (RUS)
  • Somalia (SOM)
  • South Sudan (SSD)
  • Sudan (SDN)
  • Syria (SYR)
  • Ukraine (UKR, including regions under occupation)
  • Venezuela (VEN)
  • Yemen (YEM)
  • Zimbabwe (ZWE)

Note:
This list is subject to change. Updates may be made in response to international sanctions, regulatory guidance, or internal risk assessments. Users will be notified of significant updates when applicable.

5. Customer Due Diligence (CDD) and Verification

To comply with AML requirements and before processing any payout or withdrawal, all users must complete identity verification:

  • Upload a scan or photo of your passport or ID card (JPEG, PNG, or PDF format).
  • Upload a Proof of Address document, utility bill or bank statement issued not older than 3 month ago (JPEG, PNG, or PDF format).
    We may request additional documents or information if needed.
    Failure to complete verification will result in account suspension and inability to withdraw funds.

6. Monitoring and Reporting

  • All transactions and user accounts are monitored for suspicious or unusual activity.
  • Any transaction suspected of being linked to criminal activity, fraud, or terrorism financing will be reported to the National Crime Agency (NCA) or relevant authorities.
  • All records, including verification documents and transaction logs, are retained for at least five (5) years in accordance with UK law.

7. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied when a transaction or user presents a higher risk, such as:

  • Residency in a high-risk jurisdiction.
  • Politically Exposed Person (PEP) status.
  • Unusually large or complex transactions inconsistent with typical user activity.

8. Sanctions and Blocking of Transactions

We reserve the right to:

  • Block or freeze any account if there are reasonable grounds to suspect involvement in money laundering, terrorist financing, or sanctions violations.
  • Refuse to process withdrawals or payments until satisfactory clarification or verification is obtained.
  • Report blocked accounts and transactions to the competent authorities without prior notice to the user.

9. User Responsibilities

Users must:

  • Provide accurate and complete information during registration and verification.
  • Keep their account credentials secure.
  • Use our services only for lawful and legitimate purposes.
  • Notify us immediately if they detect any unauthorized activity.

10. Non-Compliance

Failure to comply with this AML Policy may result in:

  • Account suspension or termination.
  • Forfeiture of referral commissions or balances.
  • Reporting to law enforcement agencies.
  • Legal action, including potential criminal prosecution.

11. Review and Updates

This policy is reviewed annually or sooner if required by changes in legislation, sanctions, or internal compliance procedures.
Any substantial updates will be communicated to users via email or through the platform.