Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

HolaSpain

Zuletzt aktualisiert: 12. Februar 2026.

1. Purpose

HolaSpain is committed to preventing money laundering, terrorist financing, fraud, and other financial crimes. This Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy outlines the procedures we implement in accordance with the Criminal Justice (Money Laundering and Terrorist Financing) Acts (Ireland), EU Anti-Money Laundering Directives, and other applicable Irish and EU regulatory requirements.

2. Scope

This Policy applies to students and programme participants, insurance customers, group organisers, corporate clients, and third-party payers engaging with HolaSpain.

3. Risk-Based Approach

HolaSpain applies a risk-based approach to AML compliance. We assess risk based on factors including customer location, country of destination, payment method, transaction size, and, where applicable, complex ownership structures.

4. Customer Due Diligence (CDD)

4.1 Identity Verification

We may require identity verification before processing certain transactions. Acceptable documentation may include a valid passport, national identity card, and proof of residential address. Verification requirements may vary depending on the risk assessment of the transaction.

4.2 Enhanced Due Diligence (EDD)

Enhanced checks may apply where transactions involve high-risk jurisdictions, where Politically Exposed Persons (PEPs) are involved, or where unusual payment patterns are detected. In such cases, additional documentation and verification procedures may be required.

4.3 Third-Party Payments

Where payment is made by a third party, we may request identification of the payer, proof of relationship to the beneficiary, and confirmation of the source of funds.

5. Source of Funds

In certain circumstances, particularly for large transactions, multiple payments, or corporate group bookings, HolaSpain may request evidence of the source of funds to ensure compliance with applicable AML regulations.

6. Ongoing Monitoring

We monitor transactions and client relationships for unusual or suspicious activity. Where concerns arise, additional verification or documentation may be required before proceeding.

7. Suspicious Transaction Reporting

If HolaSpain suspects money laundering, terrorist financing, or other financial crime, we may delay or refuse a transaction, request additional information, and report the matter to the relevant Irish authorities as required by law. We are legally prohibited from disclosing to the customer if a Suspicious Transaction Report (STR) has been submitted.

8. Refusal of Service

HolaSpain reserves the right to refuse service, delay transactions, or cancel bookings where adequate verification is not provided or where compliance concerns arise.

9. Record Keeping

In accordance with Irish law, we retain AML-related records for the legally required period following the end of the business relationship.

10. Data Protection

Personal data collected for AML purposes is processed in accordance with our Privacy Policy. Such data may be shared with competent authorities where legally required.

11. Staff Training & Internal Controls

HolaSpain maintains internal AML awareness procedures and applies appropriate compliance safeguards designed to prevent financial crime.

12. Limitation of Liability

HolaSpain shall not be liable for losses arising from regulatory reporting obligations, transaction delays due to verification requirements, or refusal of service based on compliance risk.

13. Governing Law

This AML & KYC Policy is governed by the laws of Ireland, and any disputes shall be subject to the exclusive jurisdiction of the Irish courts.