KYC and AML Policy - Aimer Merchants Ltd.

Official Policy Document

Effective Date: 2 June 2026
Last Updated: 2 June 2026

This KYC and AML Policy explains how Aimer Merchants Ltd. approaches client identification, verification, source of fund review, source of income review, anti-money laundering awareness, anti-terrorist financing awareness, suspicious activity prevention, document verification, and ethical service delivery.

This policy applies to clients, prospective clients, investors, business owners, company representatives, authorized persons, partners, vendors, and any individual or organization requesting services from Aimer Merchants Ltd.

By using our website, contacting us, submitting documents, requesting consultation, or engaging us for any professional service, you acknowledge and agree to this KYC and AML Policy.

1. About Aimer Merchants Ltd.

Aimer Merchants Ltd. is a Bangladesh-based professional consultancy firm providing services related to wealth management, tax and VAT consultancy, IPO consultancy, accounting services, legal documentation, capital market investment guidance, and business advisory support.

Our contact details are:

Aimer Merchants Ltd.
Shams Parasol, Flat C1, House 5, Road 21, Gulshan 1, Dhaka-1212, Bangladesh
Email: info@aimermerchants.com
Alternative Email: aimer.merchants@gmail.com
Phone: +880 1726 685 550
WhatsApp: +880 1726 685 550

2. Purpose of This Policy

The purpose of this policy is to help Aimer Merchants Ltd. maintain a responsible, transparent, and compliance-conscious service environment.

This policy is designed to:

Verify client identity where required
Understand client background and service purpose
Prevent misuse of our services
Avoid supporting illegal or suspicious activities
Reduce fraud and document manipulation risk
Identify potential money laundering or terrorist financing concerns
Promote lawful tax, VAT, investment, accounting, and documentation practices
Support professional integrity
Protect Aimer Merchants Ltd., its clients, partners, and stakeholders

3. Meaning of KYC

KYC means “Know Your Customer” or “Know Your Client.” It is the process of identifying and understanding a client before providing certain professional, financial, investment, documentation, or advisory services.

KYC may include collecting and reviewing:

Client identity
Contact information
Business information
Ownership details
Source of income
Source of fund
Service purpose
Authorized representative details
Beneficial ownership information
Relevant supporting documents

KYC helps ensure that services are provided to genuine clients for lawful purposes.

4. Meaning of AML

AML means “Anti-Money Laundering.” It refers to policies, procedures, and controls intended to prevent criminals from using legitimate businesses, financial systems, investments, professional services, or documentation channels to hide or move illegal funds.

Money laundering may involve attempts to disguise the origin, ownership, movement, or purpose of funds obtained through illegal activities.

Aimer Merchants Ltd. does not support money laundering, terrorist financing, fraud, tax evasion, fake documentation, illegal investment activity, or any unlawful financial arrangement.

5. Scope of This Policy

This policy applies to services including but not limited to:

Wealth management advisory
Investment planning support
Capital market guidance
IPO consultancy
Tax consultancy
VAT consultancy
Accounting services
Legal documentation support
Company documentation
Business advisory
Financial planning
Professional partner coordination
Client onboarding
Document review
Referral or coordination with banks, brokerage firms, asset management companies, accountants, auditors, lawyers, or other professionals

The level of KYC required may vary depending on the service type, client profile, transaction nature, risk level, document sensitivity, and partner or regulatory requirements.

6. Client Identification Requirements

Aimer Merchants Ltd. may request identity information from clients before providing certain services.

For individual clients, we may request:

Full name
Phone number
Email address
Residential address
Occupation or profession
National ID
Passport, where applicable
Photograph, where required
TIN certificate, where relevant
Source of income details
Bank information, where required for service purpose
Nominee or family details, where required for investment or wealth planning

For business clients, we may request:

Company or business name
Trade license
TIN certificate
BIN certificate, where applicable
RJSC documents, where applicable
Memorandum and Articles of Association, where applicable
Partnership deed, where applicable
Board resolution, where applicable
Ownership information
Director or shareholder information
Authorized representative information
Business address
Nature of business
Bank statements or financial records, where required
Source of fund or business income details
Tax and VAT documents, where relevant

7. Beneficial Ownership Information

For companies, partnerships, trusts, investment structures, or business entities, Aimer Merchants Ltd. may request information about beneficial owners.

Beneficial owners are individuals who ultimately own, control, or benefit from a business or transaction.

We may request beneficial ownership information to understand:

Who owns the business
Who controls the business
Who benefits from the service
Who is authorizing the transaction
Whether there are hidden owners or undisclosed controllers
Whether the business structure is being used for unlawful purposes

Clients must provide accurate and complete ownership information where requested.

8. Authorized Representative Verification

If a person contacts Aimer Merchants Ltd. on behalf of another individual, company, family, investor, or organization, we may request proof of authority.

This may include:

Authorization letter
Board resolution
Power of attorney
Email confirmation from the owner or director
Official company letterhead instruction
Identity document of the representative
Contact confirmation from the principal client

Aimer Merchants Ltd. may refuse to share information or provide service if the representative’s authority is unclear.

9. Source of Fund and Source of Income

For wealth management, investment, IPO, capital market, large transaction, documentation, or financial advisory services, Aimer Merchants Ltd. may request information about source of fund or source of income.

Source of fund may include:

Salary income
Business income
Professional income
Freelancing income
Rental income
Sale of property
Sale of business asset
Investment income
Dividend income
Savings
Inheritance
Gift
Remittance
Loan
Partnership income
Other lawful income sources

Clients must provide truthful and documented information when source of fund or source of income is required.

10. Documents We May Request

Depending on the service, Aimer Merchants Ltd. may request documents such as:

National ID
Passport
TIN certificate
BIN certificate
Trade license
RJSC documents
Bank statements
Salary certificate
Tax return documents
VAT return documents
Financial statements
Audit reports
BO account documents
Investment statements
Shareholding documents
Board resolution
Partnership deed
Rental agreement
Sale deed
Gift deed
Loan documents
Import-export documents
Source of fund evidence
Source of income evidence
Any other document reasonably required for service delivery or verification

We may refuse or delay service if required documents are not provided.

11. Politically Exposed Persons

A politically exposed person, commonly known as a PEP, may include individuals who hold or have held important public functions, as well as certain family members or close associates of such persons.

Aimer Merchants Ltd. may apply enhanced review where a client, beneficial owner, or related person appears to be a PEP.

Enhanced review may include:

Additional identity verification
Source of fund review
Source of income review
Management approval
Additional documentation
Review of transaction purpose
Ongoing monitoring where applicable

Being a PEP does not automatically mean service will be refused. However, additional caution may be required.

12. High-Risk Clients or Services

Some clients, services, transactions, or instructions may require enhanced due diligence.

High-risk indicators may include:

Unclear source of fund
Unusual transaction size
Complex ownership structure
Use of multiple unrelated accounts
Reluctance to provide documents
Use of nominees without explanation
Cash-heavy business without proper records
Inconsistent tax documents
Unexplained wealth
Offshore structure without clear purpose
Urgent pressure to process without review
Refusal to disclose beneficial ownership
Request for backdated or false documents
Suspicious investment activity
Unusual third-party payment

Aimer Merchants Ltd. may request additional documents, delay service, refuse service, or terminate service where risk is unacceptable.

13. Prohibited Activities

Aimer Merchants Ltd. does not provide support for:

Money laundering
Terrorist financing
Proliferation financing
Tax evasion
VAT evasion
Fraud
Fake documentation
Forged signatures
Hidden ownership arrangements
Illegal fund transfer
Bribery or corruption
Undisclosed illegal income
False return filing
Manipulated accounting records
Fake invoices
Fake VAT challans
Market manipulation
Insider trading
Illegal investment schemes
Unlicensed financial activity
Sanctions evasion
Any service prohibited by applicable law

If a client requests such activity, Aimer Merchants Ltd. may immediately refuse or terminate the service.

14. Suspicious Activity Indicators

Aimer Merchants Ltd. may treat the following as suspicious indicators:

Client refuses to provide identity documents
Client provides inconsistent information
Client submits unclear or altered documents
Client gives conflicting explanations about source of fund
Client requests false income or expense reporting
Client wants to hide beneficial ownership
Client insists on unusual urgency
Client asks to avoid normal documentation
Client uses unrelated third-party payment without explanation
Client asks for backdated documents
Client refuses written communication
Client requests service that appears unlawful
Client provides documents that appear forged
Client avoids tax, VAT, or regulatory questions
Client changes instructions repeatedly without clear reason

Suspicious indicators do not always prove wrongdoing, but they may require additional review.

15. Refusal or Termination of Service

Aimer Merchants Ltd. reserves the right to refuse, suspend, or terminate service if:

KYC information is incomplete
Required documents are not provided
Information appears false or misleading
Documents appear forged or altered
Source of fund is unclear
Beneficial ownership is hidden
Service request appears illegal or unethical
Client refuses reasonable verification
Client behaves abusively or dishonestly
Service may create legal, regulatory, reputational, or compliance risk
Continuing the service is not appropriate

Aimer Merchants Ltd. is not obligated to provide detailed reasons if doing so may create legal, compliance, security, or confidentiality concerns.

16. Third-Party and Partner Requirements

Some services may involve banks, brokerage firms, asset management companies, merchant banks, legal professionals, auditors, accountants, government authorities, regulatory bodies, or other third-party organizations.

These third parties may apply their own KYC, AML, document verification, risk assessment, and compliance requirements.

Clients may need to provide additional documents or information directly to third parties.

Aimer Merchants Ltd. is not responsible for third-party acceptance, rejection, delay, account opening decision, investment approval, compliance review, or document requirement.

17. Capital Market and Investment-Related KYC

For capital market, IPO, BO account, portfolio, wealth management, or investment-related services, clients may be required to provide additional documents and information.

This may include:

National ID
Bank account information
Photograph
Signature
Nominee details
TIN certificate
BO account information
Source of fund
Investment objective
Risk tolerance
Existing portfolio information
Income source
Beneficial ownership information
Regulatory documents required by partner organizations

Investment-related KYC may be required by brokerage firms, asset management companies, merchant banks, capital market intermediaries, or other authorized entities.

18. Tax, VAT, and Accounting-Related KYC

For tax, VAT, and accounting services, Aimer Merchants Ltd. may need to understand the client’s identity, business activities, source of income, transaction records, and compliance history.

Clients may be required to provide:

TIN
BIN
Trade license
Bank statements
Sales and purchase records
Tax return copies
VAT return copies
TDS/VDS challans
Salary records
Expense vouchers
Financial statements
Business ownership details
Source of income information

Aimer Merchants Ltd. does not assist with false tax reporting, VAT evasion, hidden income, or manipulated accounting.

19. Legal Documentation-Related KYC

For legal documentation support, company documents, agreements, authorization letters, property-related documents, or business documents, Aimer Merchants Ltd. may verify the identity and authority of the persons involved.

We may request:

Identity documents
Ownership proof
Authorization letter
Company documents
Board resolution
Power of attorney
Relevant supporting records
Contact verification
Other documents needed to confirm authority

We may refuse to prepare or process documents where ownership, authority, or legality is unclear.

20. Recordkeeping

Aimer Merchants Ltd. may retain KYC and AML-related records for service delivery, compliance, legal protection, dispute resolution, audit support, internal review, and professional recordkeeping.

Records may include:

Identity documents
Business documents
Service request records
Communication records
Verification notes
Source of fund documents
Source of income documents
Client approvals
Transaction-related documents
Third-party coordination records

Retention periods may vary depending on service type, legal requirements, client relationship, and business needs.

21. Confidentiality of KYC Information

KYC and AML-related information is treated as confidential and handled according to our Privacy Policy and Client Confidentiality Policy.

However, such information may be shared with authorized professionals, partners, government authorities, regulatory bodies, banks, brokerage firms, asset management companies, or legal authorities where required for service delivery, verification, compliance, or legal obligations.

22. No Cash Handling Policy

Aimer Merchants Ltd. does not encourage unnecessary cash transactions for professional service payments or client-related financial arrangements.

Where possible, clients should use transparent and traceable payment methods such as:

Bank transfer
Account payee cheque
Mobile financial service
Official payment gateway
Other documented payment methods

Clients may be requested to provide payment proof or transaction reference.

23. Third-Party Payments

If payment is made by a person or entity other than the client, Aimer Merchants Ltd. may request explanation and verification.

Third-party payments may require:

Payer name
Relationship with client
Payment proof
Reason for third-party payment
Authorization from the client
Identity verification of payer, where required

Unexplained third-party payments may be rejected or held for review.

24. Sanctions and Restricted Parties

Aimer Merchants Ltd. may refuse service if a client, beneficial owner, representative, or related party is found or reasonably suspected to be connected with sanctioned, restricted, prohibited, fraudulent, or illegal activity.

We may also refuse service where providing support could expose Aimer Merchants Ltd. to legal, regulatory, reputational, or compliance risk.

25. Ongoing Monitoring

For ongoing services, Aimer Merchants Ltd. may periodically update client information or request updated documents.

This may be required when:

Client information changes
Business ownership changes
Service scope changes
Transaction pattern changes
New risk information appears
Documents expire
Third-party partners request updated KYC
Regulatory requirements change
Ongoing advisory relationship continues

Clients should promptly inform us of any material changes in identity, business, ownership, source of fund, tax status, or contact information.

26. Client Duty to Cooperate

Clients must cooperate with reasonable KYC and AML requests.

This includes:

Providing accurate information
Submitting required documents
Explaining source of fund
Disclosing beneficial ownership
Identifying authorized representatives
Updating information when changed
Responding to verification questions
Avoiding false or misleading statements

Failure to cooperate may result in delay, refusal, suspension, or termination of service.

27. No Guarantee of Approval by Third Parties

Completing KYC with Aimer Merchants Ltd. does not guarantee approval, acceptance, account opening, investment eligibility, IPO processing, banking service, brokerage service, asset management service, regulatory clearance, or third-party onboarding.

Third-party organizations may conduct their own independent KYC, AML, risk, and compliance review.

28. Training and Awareness

Aimer Merchants Ltd. may provide internal awareness to its team regarding:

KYC requirements
Document handling
Suspicious activity indicators
Client verification
Confidentiality
Ethical service delivery
Fraud prevention
Legal and regulatory sensitivity
AML/CFT awareness

This helps maintain professional standards in client service.

29. Limitation of Liability

Aimer Merchants Ltd. takes reasonable steps to apply KYC and AML awareness within the scope of its services. However, we are not responsible for losses, delays, rejections, penalties, or third-party decisions caused by:

False client information
Forged documents
Hidden ownership
Unclear source of fund
Client refusal to cooperate
Third-party compliance decisions
Regulatory action
Bank or brokerage rejection
Authority requirements
Suspicious activity review
Client-side misconduct

Clients remain responsible for the accuracy, legality, and authenticity of information and documents provided.

30. Updates to This Policy

Aimer Merchants Ltd. may update this KYC and AML Policy from time to time to reflect changes in services, legal requirements, regulatory guidance, partner requirements, risk management practices, or business operations.

The updated version will be posted on our website with the revised “Last Updated” date.

Continued use of our website or services after updates are posted means you accept the revised KYC and AML Policy.

31. Contact Us

For questions about this KYC and AML Policy or document verification requirements, please contact us: