AML & KYC Statement

1. Commitment

Harker International, the operator of SriLankaExport.com, is committed to preventing the use of the platform for money laundering, terrorist financing, or the financing of the proliferation of weapons of mass destruction. We comply with applicable Sri Lankan AML legislation and respect the standards set by the Financial Action Task Force (FATF).

2. Applicable Law

• Financial Transactions Reporting Act No. 6 of 2006 (Sri Lanka).
• Prevention of Money Laundering Act No. 5 of 2006 (Sri Lanka).
• Convention on the Suppression of Terrorist Financing Act No. 25 of 2005 (Sri Lanka).
• FATF Recommendations as applied through Sri Lankan regulation.
• Where Buyers or Vendors are subject to AML regimes in their own jurisdictions (EU AMLD6, UK MLR 2017, US BSA), those parties remain responsible for their own compliance.

3. Vendor KYC (Know-Your-Vendor)

All Vendors are subject to internal marketplace review before listing. We collect, review, and (where applicable / lawful) verify:

• Business registration certificate (Sri Lankan Department of Registrar of Companies).
• EDB registration / directory listing details where applicable (vendor-reported; EDB registration is voluntary under the current EDB policy, the previous mandatory scheme was revoked by Gazette 2118/60, April 2019).
• Beneficial-owner identification for entities (passport / NIC of directors and 25%+ shareholders).
• Bank account details and confirmation (small-transfer verification or bank reference).
• Product certifications (where they form part of the listing).

The Vendor KYC review is an internal marketplace process for fraud prevention and platform integrity. It does not constitute approval, endorsement, or certification by EDB, the Government of Sri Lanka, or any government authority, see 마켓플레이스 검증 정책 그리고 Government Affiliation Disclaimer.

4. Buyer Due Diligence

For routine Buyers, basic identity and contact data is collected at registration. For higher-risk profiles (large transaction values, sensitive destination countries, politically exposed persons), we apply enhanced due diligence:

• Verification of company registration.
• Beneficial-owner identification.
• End-use and end-user statement.
• Source-of-funds inquiry on transactions over USD 50,000.

5. Sanctions Screening

Vendor and Buyer accounts are screened at onboarding and on a recurring basis against:

• OFAC Specially Designated Nationals (SDN) list.
• EU Consolidated Sanctions list.
• UK OFSI Consolidated list.
• UN Security Council Consolidated list.

자세한 내용은 Export Compliance & Trade Sanctions Policy for the operational detail.

6. Transaction Monitoring

We monitor transactions on the platform for indicators of:

• Structuring (multiple sub-threshold transactions designed to evade reporting).
• Unusual product mix or volumes for the Vendor’s historical profile.
• Destinations or routings inconsistent with the trade narrative.
• Third-party payment instructions inconsistent with the Buyer of record.

High-value, unusual, restricted, or high-risk product transactions, or inconsistent transactions may be delayed, rejected, refunded, or escalated for additional review at our discretion.

6a. Payment Providers & Funds Handling

SriLankaExport.com works exclusively with licensed and reputable banks and payment service providers (currently BACS to Hatton National Bank Sri Lanka, with card payments through Stripe). Buyers pay the vendor through one of these channels; the marketplace records the transaction but does not act as a money transmitter unless expressly authorized in writing.

SriLankaExport.com does not hold buyer funds itself on behalf of vendors without prior legal review, written authorization, and compliance with the Sri Lanka Payment and Settlement Systems Act No. 28 of 2005 (which restricts the operation of payment systems to entities authorized by the Central Bank of Sri Lanka). Where a buyer chooses escrow, the funds are held by Escrow.com, a licensed third-party escrow service, under its own compliance checks.

7. Politically Exposed Persons (PEPs)

PEPs are screened at onboarding using commercially available data. Transactions involving a PEP or PEP-related party are subject to enhanced review and, where required, senior-management sign-off.

8. Suspicious Transaction Reporting

Where a transaction or pattern raises a reasonable suspicion of money laundering or terrorist financing, we are required to report it to the Sri Lankan Financial Intelligence Unit (FIU). We are prohibited from “tipping off” the subject of a report; users will not be informed if a report has been made.

9. Record Retention

KYC records, transaction records, and suspicious-transaction reports are retained for at least 6 years from the end of the customer relationship or the date of the transaction, per Sri Lankan law.

10. Training & Governance

Operations staff receive AML/KYC training at onboarding and annually thereafter. The Compliance Officer reports to the Managing Director and has independent authority to suspend transactions pending review.

11. Reporting Concerns

Concerns about AML, sanctions, or fraud may be reported confidentially to info@harker.international. Whistleblower reports are protected; we do not retaliate against reporters acting in good faith.