Anti-Money Laundering & Know your Customer Policy
of Get Jet limited (trading as GetJet Travel)
Updated as of April 09, 2026
1. Introduction
This Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “AML/KYC Policy” ) of Get Jet
Limited, a company duly incorporated under the laws of Malta with company
registration number ,
VAT number ,
and having its registered office at Suite 64B Regent House,
Triq Bisazza, Sliema, SLM 1640,
Malta (hereinafter referred to as “Company” ),
trading under the brand name “GetJet Travel”
, is designated to prevent and mitigate, so far as is possible within the remit of Maltese and EU law, any possible risks of the
Company being involved in any kind of illegal activity.
The Company acts as an air charter broker and does not own, operate or control any aircraft. All flights are
operated by licensed third-party air carriers holding valid Air Operator Certificates (AOC).
Both international and local regulations, as well as the Company`s agreements and policies, require that the
Company implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing,
the use of the proceeds of a criminal activity in a transaction, drug and human trafficking, proliferation of
weapons of mass destruction, corruption, bribery, and to consider international sanctions (and other restrictive
measures, as may be applicable) and to take action in case of any form of suspicious activity from its
clients.
The Company is classified as a “subject person” under Maltese and EU anti-money laundering regulations due to the
nature of its services (arranging private jet charters, where the value of individual transactions and the
underlying aircraft significantly exceeds the thresholds established for high-value goods).
2. Verification Procedures
2.1. Risk-Based Approach
The Company shall adopt a risk-based approach in identifying and assessing the money laundering / terrorist
financing risks to which it may be exposed, and shall adapt its measures, policies, controls and procedures as
may be required to ensure its resources are utilised where most needed.
2.2. Sanctions Screening
The Company is to carry out sanction screening on the names of all customers, directors/administrators and/or
beneficial owners, as may be applicable, against sanctions lists and other adverse media, via reputable
commercial databases. The Company is to also adhere to and follow any new sanctions or other restrictive
measures which may be imposed and keep abreast of any guidance, notices, decisions, recommendations or rulings
that may be issued by the Sanctions Monitoring Board of Malta, in terms of the National Interest (Enabling
Powers) Act (Act XX of 1993, as subsequently amended).
2.3. Customer Due Diligence (CDD)
One of the international standards for preventing illegal activity is Customer Due Diligence (CDD) . According to
CDD, the Company is to establish its own identification and verification procedures within the standards of
anti-money laundering and “Know Your Customer” (KYC) frameworks and in terms of local and EU legislation.
The Company's identity verification procedure requires the Client to provide the Company with reliable,
independent source documents, data and/or information (e.g., national ID, international passport). For such
purposes, the Company reserves the right to collect the Clients identification information for the AML/KYC
Policy purposes.
The Company will take steps to confirm the authenticity of documents and information provided by the Client. All
legal methods for double-checking identification information will be used, and the Company reserves the right to
request further information and/or documentation from any Client who has been determined to be risky or
suspicious.
2.4. Ongoing Monitoring
The Company reserves the right to verify the Clients identity on an ongoing basis, especially when the Clients
activity seems to be suspicious (unusual for the particular Client). In addition, the Company reserves the right
to request up-to-date documents from the Client, even though the Client passed identity verification in the
past. The Company shall also be required to carry out ongoing monitoring and transaction monitoring in terms of
its obligations established under Maltese and EU law.
2.5. Data Protection
Client identification information will be collected, stored, shared and protected strictly in accordance with the
Company's Privacy Policy and related regulations (including the General Data Protection Regulation (GDPR)).
2.6. Legal Effect
Once the Client`s identity has been verified, the Company will be able to absolve itself of potential legal
liability in a situation where its Services are used to conduct illegal activity.
3. Anti-Money Laundering (AML) Policy
3.1. Zero Tolerance
The Company enforces a strict anti-money laundering policy with zero tolerance towards money laundering and
terrorist financing activities. The Company defines the term “money laundering” as “the process through which
the illegal nature of criminal proceeds is concealed or disguised in order to give a legitimate appearance to
these illegal proceeds.”
This AML/KYC Policy also refers and adheres to the definition of “money laundering” as defined in the Prevention
of Money Laundering Act (Cap. 373 of the Laws of Malta) , as subsequently amended.
3.2. Client Undertakings
All Clients of Get Jet Limited undertake to comply with this AML/KYC Policy and with all applicable local and EU
anti-money laundering, counter‑financing of terrorism (CFT) and sanctions laws and regulations. Failure to
comply can result in severe consequences such as criminal penalties and heavy fines.
The Company shall ensure complete compliance with laws pertaining to anti‑money laundering through this AML/KYC
Policy.
3.3. Client Acknowledgements
All Clients acknowledge, undertake and agree to the following terms regarding their use of the Company`s website
(www.getjettravel.com) and mobile application GetJet Travel (collectively referred to as the “Service” and/or
“Services” ):
3.3.1.
The Client will comply (throughout his/her/its time as the Company`s client) with all relevant statutes, laws and
regulations pertaining to money laundering, funding of terrorism and sanctions.
3.3.2.
Get Jet Limited operates under certain obligations known as “know‑your‑client” (KYC) obligations which grant the
Company the right to implement anti‑money laundering procedures to help detect and prevent any money laundering
and/or terrorist financing activities regardless of the location of such activity.
3.3.3.
The Client agrees to lend full cooperation to Get Jet Limited with respect to its anti‑money laundering efforts
and to provide documentation as may from time‑to‑time be required in terms of the Company`s requests in order to
fulfill its AML/CFT obligations. This includes, inter alia, the provision of documentation and/or information by
the Client to the Company for the purpose of assisting it in the performance of its duties as dictated by
applicable laws and regulations, regardless of jurisdiction.
3.3.4.
Get Jet Limited reserves the right to delay or stop the provision of any Services contracted by the Client,
and/or any subscriptions to any Service to the Client, if the Company has reason to believe that any transaction
may result in the violation of any applicable law or is contrary to acceptable practices. Get Jet Limited may
also delay or stop the provision of any Services, and/or any subscriptions to any Service to the Client, if it
is known or suspected that the Client may have been, is, or may be engaged in money laundering and/or funding of
terrorism activities.
3.3.5.
Get Jet Limited may use the Client`s information for the investigation and/or prevention of fraudulent or
otherwise illegal activities.
3.3.6.
Get Jet Limited has the right to share the Client`s information with:
- A. Investigative agencies or any authorised officers helping Get Jet Limited to comply with applicable law,
including anti‑money laundering laws and know‑your‑client obligations;
- B. Organisations that help Get Jet Limited to provide the Services it offers to its Clients;
- C. Government, law enforcement agencies and courts;
- D. Regulatory bodies and financial institutions.
This right to share shall be exercised after the Company`s Money Laundering Reporting Officer (MLRO) / designated
employee has considered an internal report made by an employee of Get Jet Limited, which was submitted together
with all accompanying documentation in relation to such internal report.
Such right to share shall be exercised after considering such internal report and when the Company`s
MLRO/designated employee knows / suspects / has reasonable grounds to suspect that:
- (i) a transaction or an attempted transaction may be related to money laundering or funding of terrorism;
or
- (ii) a person may have been / is / may be connected with money laundering or funding of terrorism; or
- (iii) money laundering or funding of terrorism has been / is being / may be committed / attempted.
Such Client information and the fact that the information has been, will be, or may be shared for the purpose of
a possible or actual investigation (as per this Clause 3.3.6) shall not be disclosed by the Company to the
Client.
3.3.7.
Get Jet Limited adopts three stages of Client verification process to ensure stricter anti‑money laundering
activity:
- A. Know‑Your‑Customer (KYC) measure – Get Jet Limited shall identify the Client prior to providing Services.
However, the Company retains the right to require the Client to periodically review the documentation and
information provided if at any time the Company believes that information provided is incomplete or
inaccurate, or if the Company believes that somebody stole the Client`s Account credentials, or in terms of
its obligations to carry out ongoing monitoring under Section 3.3.7(C) below.
- B. Verification – AML verification of the Client`s information and payment data. The Client shall undergo an
AML verification process of all documents provided, together with confirming Source of Wealth (SoW) and
Source of Funds (SoF) , where applicable, to ensure their lawful origin.
- C. Ongoing Monitoring – Throughout the business relationship with the Client, the Company shall carry out
ongoing monitoring of the Client, through transaction monitoring and the maintenance of information,
documentation and data of the Client.
4. Know Your Customer (KYC) and AML Verification
4.1. Mandatory KYC Check
The Client acknowledges that he/she/it is to complete a KYC check before subscribing to the Service, which must
be in form and substance satisfactory to Get Jet Limited. The KYC check is to be carried out prior to the
provision of any Services by providing necessary information with regard to identification of the Client,
beneficial owner, origin of wealth and, where applicable, origin of funds. The scope and type of information
depend on the type of Client (individual or corporate).
4.2. Required Documents
4.2.1. For an Individual Client:
A high‑resolution scanned copy or photo of pages of:
- a valid passport (indicating official name and surname, date and place of birth, nationality, passport
number, issue and expiry dates, country of issue); or
- for citizens of the EU, any other national ID card (with equivalent information);
- proof of permanent residential address (e.g., utility bill or bank statement not older than 3 months,
showing name, address and postcode);
- the Client`s signature (on a separate document or as part of the ID).
4.2.2. For a Corporate Client:
A high‑resolution copy of constituent documents, including but not limited to:
- Certificate of Incorporation (or equivalent);
- Certificate of Change of Name (if applicable);
- Certificate of Good Standing (if applicable);
- Articles of Incorporation / Memorandum & Articles of Association;
- Register of Directors and Shareholders;
- Identification documents of the Ultimate Beneficial Owner(s) (UBO) – any individual who ultimately owns or
controls more than 25% of the shares or voting rights.
4.3. Enhanced Due Diligence (EDD) for HNWI / UHNWI Clients
Given that the Company`s typical clients are High Net Worth Individuals (HNWI) and Ultra-High Net Worth
Individuals (UHNWI) with investable assets starting from €1,000,000, and given the high‑value nature of the
transactions (charter flights starting from €10,000 per seat and up to €70,000+ for whole aircraft), Get Jet
Limited shall apply Enhanced Due Diligence (EDD) measures for all clients, including:
- Obtaining additional information on the Client`s Source of Wealth (SoW) (how the Client accumulated their
wealth over time);
- Obtaining additional information on the Source of Funds (SoF) (the specific funds used for the particular
transaction);
- Review and updating of information at least once every 12 months (or more frequently if the risk profile
increases);
- Senior management approval before establishing or continuing the business relationship.
4.4. Cooperation
The Client shall undertake to collaborate with regard to the AML/KYC check and to provide any information and
document deemed necessary by Get Jet Limited.
4.5. Right to Reject
Get Jet Limited may reject any Client in its sole discretion without specifying a reason for the rejection,
particularly if the Client fails to provide required KYC/EDD documentation or if the information provided raises
suspicions.
5. Record Keeping
Get Jet Limited shall keep all records obtained under this AML/KYC Policy (including identification documents,
transaction records, and correspondence) for a period of at least five (5) years after the termination of the
business relationship with the Client, or longer if required by Maltese law or applicable EU regulations.
6. Money Laundering Reporting Officer (MLRO)
Get Jet Limited has appointed a Money Laundering Reporting Officer (MLRO) who is responsible for:
- Receiving internal reports of suspected money laundering or terrorist financing;
- Considering such reports and determining whether they should be disclosed to the Financial Intelligence
Analysis Unit (FIAU) of Malta;
- Acting as the point of contact with law enforcement and regulatory authorities on AML/CFT matters;
- Ensuring the Company`s compliance with all AML/CFT obligations.
MLRO contact:
Email: privacy@getjettravel.com
7. Training
The Company shall provide regular AML/CFT training to all relevant employees (including management, sales, and
finance teams) to ensure they are aware of their obligations under Maltese and EU law and this AML/KYC
Policy.
8. Non-Compliance and Penalties
Failure by Get Jet Limited or its employees to comply with this AML/KYC Policy may result in:
- Internal disciplinary action (up to and including termination of employment);
- Reporting to the FIAU or other competent authorities;
- Potential criminal and civil penalties against the Company and/or individuals under the Prevention of Money
Laundering Act (Cap. 373) and associated regulations.
9. Governing Law
This AML/KYC Policy shall be governed by and construed in accordance with the laws of Malta. Any disputes arising
out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts of
Malta.
10. Contact Information
For any questions or reports under this AML/KYC Policy, please contact:
Get Jet Limited (trading as GetJet Travel)
Registered address: Suite 64B Regent House,
Triq Bisazza, Sliema, SLM 1640,
Malta
Email: info@getjettravel.com
AML/KYC enquiries: privacy@getjettravel.com
Phone: +356 990 724 97
11. Amendments
Get Jet Limited reserves the right to amend this AML/KYC Policy at any time. Clients will be notified of material
changes via email or through a notice on the Company`s website. The current version is always available at
www.dev.getjettravel.com.