Skylite SRL – Anti Money Laundering and Counter Terrorist Financing Policy (AML CTF)

As of 18 November 2025

1. Purpose of this policy

This Anti Money Laundering and Counter Terrorist Financing Policy explains how Skylite SRL works to prevent its services from being used for money laundering, terrorist financing, fraud or other financial crime.

The policy applies to all activities of Skylite SRL and to all ecommerce websites operated by Skylite SRL, including their payment and refund processes and customer support interactions.

2. Company details

Legal entity: Skylite SRL
VAT number: BE0750676367

3. Regulatory framework

Skylite SRL is a Belgian company and follows the applicable Belgian and European Union rules related to anti money laundering and counter terrorist financing, including:

  • Belgian AML legislation transposing the EU Anti Money Laundering Directives
  • Requirements related to sanctions and asset freezes decided at EU and United Nations level

Skylite SRL is an ecommerce retailer and is not a bank or financial institution. Nevertheless, the company takes reasonable and proportionate measures to prevent and detect possible misuse of its services for money laundering or terrorist financing.

4. Scope and risk based approach

Skylite SRL uses a risk based approach. This means that the intensity of checks and monitoring is adapted to the level of risk identified, taking into account for example:

  • Order value and frequency
  • Payment method
  • Country of residence and delivery
  • Delivery pattern and use of third party addresses
  • Customer behaviour and communication patterns

Most retail transactions on our websites are low risk. Additional checks may be carried out in higher risk situations, such as:

  • Unusually high order values or multiple orders placed in a short period of time
  • Orders paid by bank transfer from accounts not clearly linked to the customer
  • Requests for refunds to bank accounts, cards or digital wallets different from the original payment method
  • Use of complex delivery chains or repeated changes of delivery address without clear explanation

5. Customer identification and verification

For standard online orders paid through usual card or payment processors, only basic customer details are collected, such as name, address and contact details, as required to process and ship the order.

In some situations Skylite SRL may request additional information and documents to verify the identity of the customer. For example:

  • Copy or photo of an identity document
  • Proof of address such as a utility bill or official letter
  • Confirmation that the customer is acting on their own behalf and not for a third party

Skylite SRL reserves the right to cancel an order, to delay shipping, or to refuse a refund if the requested verification information is not provided or if there are serious doubts about its authenticity.

6. Payment methods and refunds

Skylite SRL accepts only payment methods that offer a reasonable level of traceability and security, such as:

  • Credit and debit cards
  • Recognised online payment processors
  • Bank transfers to accounts in the name of Skylite SRL
  • Certain virtual asset (crypto) payment methods processed through approved service providers that apply appropriate anti-money-laundering and sanctions screening

Skylite SRL does not accept cash payments and does not knowingly accept anonymous or untraceable payments. In particular, Skylite SRL may refuse or refund payments that appear to come from privacy coins, mixers or tumblers, or from wallets associated with sanctions, fraud or other financial crime.

When virtual asset (crypto) payments are used, Skylite SRL may request additional information about the origin of funds or the customer’s identity. If sufficient information is not provided, or if the risk is considered too high, the order may be refused and, where possible, the payment returned.

7. Prohibited and high risk activities

Skylite SRL does not tolerate the use of its websites or services for illegal activities. The following situations are examples of behaviour that may be considered suspicious:

  • Attempts to use stolen or forged payment instruments
  • Repeated chargebacks or disputes without clear justification
  • Attempts to place orders clearly inconsistent with a customer’s declared identity and profile
  • Requests to ship to third party addresses that are inconsistent or repeatedly changed without valid reason
  • Attempts to circumvent our terms and conditions or to pressure staff to bypass normal procedures

Where appropriate, Skylite SRL may refuse or cancel orders, block customer accounts and exclude customers from future purchases.

8. Monitoring and detection of suspicious activity

Skylite SRL monitors transactions and customer behaviour using:

  • Automated tools from payment processors and banks to detect unusual or high risk transactions
  • Internal reviews of high value orders, unusual refund requests and complex shipping instructions
  • Manual checks by trained staff in case of alerts or doubts

If suspicious activity is detected, Skylite SRL may:

  • Request further information or documents from the customer
  • Delay or cancel the order
  • Decline to proceed with a refund or shipment until concerns are resolved

9. Reporting to authorities

When Skylite SRL has a strong suspicion that an order, payment or refund may be linked to money laundering, terrorist financing or other serious crime, and when required by applicable law, the company will report this to the competent authority.

In such cases Skylite SRL may not be allowed to inform the customer that a report has been made, in line with legal requirements on confidentiality.

10. Sanctions, restricted parties and prohibited jurisdictions

Skylite SRL will not knowingly conduct business with individuals, entities or countries that are subject to financial sanctions which prohibit the provision of goods or services.

In higher risk cases, Skylite SRL may carry out screening of customer information against publicly available sanctions or watch lists. Orders or refunds may be delayed or refused if they appear to involve a sanctioned person, entity or destination.

In line with requirements introduced by the local regulator, Skylite SRL maintains and implements a list of prohibited jurisdictions and their citizens. Skylite SRL does not accept orders from, or on behalf of, customers who are resident in, located in, or citizens of, the following jurisdictions:

  • Iran
  • North Korea
  • Myanmar
  • Russian Federation
  • Belarus

Skylite SRL may expand this list at any time to reflect new or updated sanctions or other regulatory requirements. If an order appears to involve a prohibited jurisdiction or citizen of a prohibited jurisdiction, the order may be refused, cancelled or refunded, and no further business relationship will be established.

11. Record keeping

To comply with legal requirements and to support its AML CTF framework, Skylite SRL retains relevant records for the period required by law, including:

  • Order details and invoices
  • Payment confirmations and refund records
  • Correspondence related to AML checks and verifications
  • Any internal notes or reports regarding suspicious activity

These records are kept securely and access is limited to staff who need them for their work.

12. Staff responsibilities and training

All directors and employees of Skylite SRL share responsibility for preventing and detecting money laundering and terrorist financing. In particular they must:

  • Follow the procedures described in this policy
  • Be alert to unusual customer behaviour and transaction patterns
  • Escalate any concern to the relevant director or designated compliance contact

Skylite SRL provides periodic information and guidance to staff so they can recognise common warning signs and understand the steps to take if they identify a potential issue.

13. Data protection

Skylite SRL processes personal data collected for AML and fraud prevention purposes in line with applicable data protection laws, including the General Data Protection Regulation of the European Union.

Personal data is used only for legitimate purposes such as:

  • Processing and delivering orders
  • Preventing fraud, money laundering and terrorist financing
  • Complying with legal obligations

Customers can find more information about how their data is processed in our Privacy Policy.

14. Consequences of non compliance by customers

If a customer refuses to provide requested information, provides false or misleading information, or if Skylite SRL reasonably believes that an order is linked to illegal activities, the company may:

  • Refuse or cancel the order
  • Suspend or close the customer account
  • Refuse a refund or replacement where allowed by law and by our terms and conditions
  • Report the matter to the relevant authorities

These measures are necessary to protect Skylite SRL, its customers, its banking partners and the wider financial system.

15. Policy review

This AML CTF Policy is reviewed on a regular basis and updated when necessary to reflect changes in applicable laws, regulations or in Skylite SRL’s business model.

The current version is published on Skylite SRL’s ecommerce websites so that customers and partners can understand the principles that guide our approach to compliance and financial crime prevention.

Shopping Cart
Scroll to Top