Hi Lidis,
Thanks for the question.
The fund’s obligations will depend on whether you are a reporting entity, and thus required to comply with the AML/CTF legislation. Additionally, you should be aware that refunding money to third parties represents an increase in ML/TF risk.
In short, this is a complex legal question and a range of laws apply. We would recommend that you seek professional legal advice. Please feel free to contact our financial services team.
