LEGAL · AML / KYC

AML / KYC policy

Why we run an AML programme

We are not currently a listed obliged entity under US BSA MSB rules (31 CFR § 1010.100(ff)) nor under the current EU 4th/5th AMLD framework, and the new EU AMLR (Reg. (EU) 2024/1624 — applicable 10 July 2027) lists aircraft sales >€7.5M rather than charter brokerage. We nonetheless apply a voluntary programme because banking partners require it, private aviation is regularly used by sanctioned or high-risk actors, and cash-equivalent payments at private-aviation price points routinely trigger US Form 8300 reporting.

Customer Due Diligence (CDD)

For every new charterer we collect, before confirming the first flight: full legal name; principal address and DOB (or registered office and registration number); ID for the signatory and beneficial owners (≥25%); a signed source-of-funds statement (with supporting evidence above USD 100,000); the passenger list with DOB and nationality; and the sanctions screening per our sanctions policy. We refresh ID at least every 24 months.

Enhanced Due Diligence (EDD)

We apply EDD when any of the following is present: PEPs, their immediate family or close associates; FATF grey/blacklist jurisdictions or sanctioned-sector linkages; cash or cash-equivalent instruments; payment by a third party; routes touching sanctioned jurisdictions; or unusual patterns (last-minute large bookings, frequent re-routing, split invoices). EDD requires Compliance Officer sign-off before booking and includes adverse-media screening and a written source-of-funds and source-of-wealth justification.

Cash payments and Form 8300

Cash, cashier's checks, money orders and similar instruments aggregating over USD 10,000 in a single transaction or related transactions trigger a Form 8300 filing within 15 days of receipt (26 USC § 6050I; 31 USC § 5331). We notify you in writing as required by § 6050I(e). Structuring transactions to evade the threshold is prohibited under 31 USC § 5324.

Records and training

CDD/EDD documentation is retained for the longer of 5 years (US baseline) or 10 years (EU national law). All client-facing staff complete annual training covering CDD/EDD triggers, sanctions, cash reporting, tipping-off prohibition, data protection and escalation.

Contact: compliance@thelimitlesssky.com. See also our sanctions policy and broker disclosure.