Compliance
Global Financial Crimes Compliance
Thomas Schumann Capital GmbH is committed to the highest standards of financial crime prevention. This page outlines our compliance framework covering anti-money laundering, sanctions, anti-bribery, and market integrity.
AML / CTF
KYC / CDD
Sanctions
Anti-Bribery
1. Our Commitment to Compliance
Thomas Schumann Capital GmbH maintains a comprehensive Global Financial Crimes Compliance (GFCC) programme designed to prevent, detect, and report financial crime in all its forms. The Firm is committed to the highest standards of integrity and operates in full compliance with applicable German, European, and international financial crime laws and regulations. The Firm is regulated by the Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) and adheres to all applicable requirements under the Wertpapierinstitutsgesetz (WpIG) and related legislation.
2. Anti-Money Laundering (AML)
The Firm maintains a robust Anti-Money Laundering programme in accordance with the German Money Laundering Act (Geldwäschegesetz — GwG) and the EU Anti-Money Laundering Directives (AMLD). Key elements of our AML programme include: — Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for higher-risk clients — Ongoing monitoring of client relationships and transactions — Risk-based assessment of clients, products, and geographies — Appointment of a designated Money Laundering Reporting Officer (MLRO) — Regular staff training on AML obligations and red flag indicators — Suspicious Activity Reporting (SAR) procedures
3. Know Your Customer (KYC)
The Firm conducts thorough Know Your Customer (KYC) procedures for all clients prior to establishing a business relationship. This includes: — Verification of identity for individuals and legal entities — Identification and verification of beneficial owners (UBOs) — Assessment of the purpose and intended nature of the business relationship — Screening against applicable sanctions lists and politically exposed persons (PEP) databases — Ongoing monitoring and periodic review of client information
4. Sanctions Compliance
The Firm maintains a comprehensive sanctions compliance programme covering all applicable sanctions regimes, including those administered by: — The European Union (EU) — The United Nations Security Council (UNSC) — The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury — His Majesty's Treasury (HMT) of the United Kingdom — The German Federal Office of Economics and Export Control (BAFA) All clients, counterparties, and transactions are screened against applicable sanctions lists prior to onboarding and on an ongoing basis.
5. Anti-Bribery and Corruption (ABC)
The Firm maintains a zero-tolerance policy towards bribery and corruption in all its forms. Our Anti-Bribery and Corruption programme is designed to comply with: — The German Criminal Code (Strafgesetzbuch — StGB) provisions on bribery — The UK Bribery Act 2010 — The U.S. Foreign Corrupt Practices Act (FCPA) where applicable All staff are required to complete regular training on anti-bribery obligations. The Firm prohibits facilitation payments and maintains strict controls over gifts, hospitality, and political contributions.
6. Market Abuse and Insider Trading
The Firm maintains policies and procedures to prevent market abuse and insider trading in accordance with the EU Market Abuse Regulation (MAR) and applicable German securities law. This includes: — Maintenance of insider lists — Pre-clearance procedures for personal account dealing — Information barriers (Chinese walls) between business areas — Regular staff training on market abuse obligations — Monitoring of communications and trading activity
7. Whistleblowing
The Firm maintains a confidential whistleblowing channel through which employees, clients, and third parties may report suspected financial crime or compliance concerns without fear of retaliation. Reports may be made to: Email: [email protected] All reports are treated with strict confidentiality and investigated promptly. The Firm prohibits retaliation against any person who makes a good-faith report of suspected wrongdoing.
8. Regulatory Reporting
The Firm fulfils all applicable regulatory reporting obligations, including: — Suspicious transaction reports (STRs) to the Financial Intelligence Unit (FIU) Germany — Reporting to BaFin as required under applicable securities and financial services legislation — Cross-border reporting obligations under applicable tax information exchange agreements (FATCA, CRS) Last updated: May 2026