Introduction
Xforeverly Single Member Banking S.A. (hereinafter “Xforeverly”), a subsidiary of Xforeverly Wallet Holdings SA, and headquartered in Athens, Greece, is regulated and supervised as a credit institution by the Bank of Greece.
Apart from its operations in Greece, it also offers a range of financial products and services to clients across 22 EU and EEA jurisdictions under the EU Freedom of Services regime, ensuring flexibility while maintaining effective oversight.
Xforeverly is committed to compliance with international standards, including:
- FATF Recommendations
- Basel Committee principles
- Wolfsberg Principles
- EU and Greek legal and regulatory frameworks
This Anti-Financial Crime Statement supplements the Wolfsberg Questionnaire and the Terms and Conditions, and communicates the Bank’s AFC policy framework, risk appetite, and commitment to transparency and integrity.
Executive Summary – Key AFC Commitments
- Commitment to International Standards: Compliance with FATF, Basel, Wolfsberg, EU, and Greek AML/CTF laws
- Strong Governance: Appointment of AFCCO/MLRO, deputy, and Board-level accountability
- Comprehensive Framework: Covers CDD/KYC, sanctions, transaction monitoring, fraud, corruption, and tax compliance (FATCA/CRS)
- Monitoring & Assurance: Includes internal audits, ongoing monitoring, and external audits every 3 years
- Defined Risk Appetite: Restrictions on shell banks, sanctioned entities, high-risk sectors, etc.
- Transparency & Cooperation: Open communication and secure whistleblowing channels
Scope of the Statement
This AFC Statement applies to:
- Employees
- EOR staff
- Vendors and contractors
All must comply with Xforeverly’s AFC standards.
Governance Framework
Xforeverly is committed to combating:
- Money laundering
- Terrorist financing
- Fraud
- Bribery & corruption
- Sanctions evasion
A designated Anti-Financial Crime Compliance Officer (AFCCO/MLRO) and deputy ensure independent oversight.
The Board of Directors retains ultimate responsibility for AML/CTF compliance.
Policies and Procedures
Xforeverly has established comprehensive AFC policies aligned with:
- Greek AML laws
- EU legislation
- FATF, Basel, Wolfsberg standards
All policies are:
- Implemented daily
- Reviewed annually or when needed
AFC Compliance Program
The program includes:
- KYC/CDD Program: Customer identification, risk classification, EDD for high-risk clients
- Mandatory Annual Training: For all staff
- Transaction Monitoring: Detection of suspicious activity
- Sanctions Compliance: Real-time screening against EU, UN, OFAC, HMT sanctions
- Fraud & Corruption Prevention: Monitoring and detection frameworks
- Tax Evasion Prevention: Compliance with FATCA and CRS
- Record Retention: Minimum 5 years
- Law Enforcement Cooperation: Full cooperation with authorities
- Risk-Based Controls: Assessments, training, and escalation procedures
Monitoring and Review Process
The AFC program is subject to:
- Ongoing monitoring
- Annual internal audit review
- External audits every 3 years
Findings are reported to senior management and the Board.
Prohibited Relationships, Sectors and Services
Xforeverly may restrict:
- Shell banks
- Unverified ownership structures
- Sanctioned entities
- High-risk jurisdictions and sectors
Includes restrictions on:
- Anonymous accounts
- Unregulated financial products
Communication with Customers
Xforeverly may request:
- Customer identity details
- Business activity information
- Transaction clarifications
Failure to comply may result in:
- Transaction delays
- Account restrictions or closure
Commitment to Continuous Compliance
Xforeverly continuously updates its AFC strategy to align with:
- Regulatory developments
- Emerging risks
- Supervisory expectations
Contact Information and Reporting
For questions or reporting suspicious activity:
Email: aml-governance@xforeverly.co.uk
Whistleblowing:
support@xforeverly.co.uk
Reports are handled confidentially and in compliance with data protection laws.
