Anti-Money Laundering (AML) and Сombating the Financing of Terrorism (CFT) Policy
A policy that describes the procedures for the prevention of money laundering and terrorist financing. The policy contains information about the fund’s risk assessment process, know-your-customer (KYC) procedures, customer assessment (CDD) procedures, suspicious activity reporting (SAR) procedures, and any other procedures related to AML and CFT compliance.
1. Policy Objective and Scope
1.1. Objective: The objective of our AML policy is to prevent the use of our service for money laundering and terrorist financing activities.
1.2. Scope: This policy applies to all clients and transactions conducted through our online service.
1.3. Compliance with Legislation: We are committed to complying with all applicable laws and regulations related to combating money laundering and terrorist financing.
1.4. Cooperation with Regulatory Authorities: We are prepared to cooperate with relevant regulatory authorities and provide them with the necessary information upon request. We adhere to the principle of full transparency and support efforts to combat money laundering and terrorist financing.
1.5. Internal Control: The company maintains strict internal control and monitoring of its activities to prevent and detect suspicious transactions.
1.6. Staff Training: We are committed to providing regular training to our staff on AML matters to ensure their knowledge and competency in the fight against money laundering and terrorist financing.
1.7. Continuous Improvement: We strive for continuous improvement of our AML policy by implementing new technologies and methods to effectively combat money laundering and terrorist financing.
1.8. Collaboration with External Experts: If necessary, we are willing to seek assistance from external experts specializing in AML to obtain advice and recommendations for improving our policy and procedures.
1.9. Reporting and Audit: We regularly report on our actions and monitor transaction activities. Additionally, we conduct internal audits to ensure compliance with our AML policy requirements.
1.10. Policy Dissemination: We are committed to distributing our AML policy among all employees and ensuring their understanding and compliance with this policy within the scope of their work.
2. Client Identification
2.1. Identity Verification: The company implements policies and procedures to ensure the identification of the identity of all new clients. Each client undergoes identity verification procedures, which inсlude collecting the following information: full name, residential address, phone number, date of birth, employment details (such as place of work and position), as well as identity documents such as a passport, national identification card, or driver’s license. For higher-risk clients, such as legal entities or individuals from high-risk countries in terms of money laundering and terrorist financing, a more detailed identity check is conducted, including beneficiary verification and additional document verification.
2.2. Information Authenticity Verification: We conduct verification of the information provided by clients and request additional documents, if necessary, to confirm the legality of their activities.
2.3. Restricted Persons and Sanctioned Entities: We maintain a list of restricted persons and sanctioned entities in accordance with applicable legislation. If a client is identified from this list, we take the measures required by the law.
2.4. Ongoing Client Due Diligence: We periodically conduct client due diligence in accordance with applicable legislative requirements and depending on the risk of the client’s transactions and activities.
3. Transaction Monitoring
3.1. Continuous Monitoring: We conduct continuous monitoring of all transactions conducted through our service. This includes monitoring financial transactions, fund movements, cryptocurrency exchanges to fiat currencies, and vice versa.
3.2. Use of Analytical Tools: To ensure effective monitoring, we utilize specialized analytical tools and technologies. These tools enable us to automatically detect unusual or suspicious transactions and analyze customer information and activities.
3.3. Risk-Based Approach: We employ a risk-based approach to transaction monitoring. This means that we allocate greater attention and resources to operations that pose a higher risk of money laundering or terrorist financing, in accordance with our internal procedures and risk criteria.
3.4. Processing of Suspicious Transactions: Upon identifying suspicious transactions, we take immediate action. This may involve requesting additional information from the client, refusing to proceed with the transaction, or notifying the relevant authorities about the suspicious activity.
3.5. Restriction of Anonymous Transactions: We do not allow users to engage in anonymous transactions or exchange cryptocurrencies without undergoing identity verification. All transactions must be tied to a specific user with verified identity information.
4. Notation and Storage of Information
4.1. Detailed Record-Keeping. The company undertakes to maintain detailed records of all transactions conducted through our service. This includes information about clients, transaction amounts, sources and purposes of funds, as well as other relevant details necessary to comply with AML policies and legal requirements.
4.2. Record Creation. The service has developed procedures for creating accurate and comprehensive records, including the collection of information, investor documentation, and various activities.
4.3. Information Storage. We ensure proper storage of all records and transaction-related information in accordance with applicable legislation. The information is stored in a secure location with limited access and strict data confidentiality measures.
4.4. Retention Period. We adhere to legally mandated retention periods for client and transaction information, and we proceed with their destruction after the expiration of the storage period, as per legal requirements.
4.5. Record Updates. The service follows procedures for updating records, especially when there are changes in investor information, transaction execution, or the detection of suspicious activity.
4.6. Access Restriction. The company applies access restrictions to records, granting appropriate rights and permissions to authorized personnel for viewing confidential information. Necessary measures are also implemented to protect records against unauthorized access and use.
4.7. Record Deletion. The company adheres to a record deletion policy following the expiration of their retention period in accordance with jurisdictional requirements, legislation, and regulatory acts.
4.8. Audit and Verification. The company complies with procedures for auditing and verifying records to ensure their accuracy, completeness, and compliance with jurisdictional requirements, legislation, and regulatory acts.
5. Cooperation with Competent Authorities.
5.1. Reporting Suspicious Transactions. We commit to promptly reporting any suspicious transactions identified through our monitoring to the competent authorities. We cooperate with the relevant agencies and provide them with all necessary information and documentation.
5.2. Collaboration in Investigations. We are prepared to fully cooperate with law enforcement agencies and participate in investigations related to money laundering and terrorist financing. We grant them access to the required data and assist in detecting and preventing illegal activities.
6. Training and Public Awareness
6.1. Staff Training. We regularly conduct training programs for our staff to ensure their understanding and adherence to AML policies. This includes training on recognizing signs of suspicious transactions, customer identification procedures, and handling suspicious situations.
6.2. Public Awareness. We also take measures to promote public awareness in the fight against money laundering and terrorist financing. We inform our clients and the general public about the risks and consequences associated with illegal financial activities and encourage all employees and users to actively participate in preventing these criminal practices.
7. Responsibility and Penalties.
7.1. Policy Compliance. Every employee is obligated to adhere to the policy on combating money laundering and terrorist financing and apply it in their work. Violation of this policy may result in disciplinary measures and even legal consequences in accordance with the law.
7.2. Compliance with Legislation. We strictly comply with all applicable laws, regulations, and regulatory requirements in the field of combating money laundering and terrorist financing. We continuously updаte our policies and procedures in accordance with legislative changes to ensure full compliance with requirements.
7.3. Internal Control and Accountability. We establish effective mechanisms for internal control and accountability to ensure compliance with AML policies. This includes assigning responsible individuals, conducting internal checks and audits, as well as monitoring the activities of our staff.
7.4. Sanctions and Cooperation with Competent Authorities. We are prepared to impose sanctions against violators of AML policies, including denying services and terminating contracts. When necessary, we cooperate with competent authorities to hold individuals involved in illegal financial activities accountable.
8. Risk Assessment.
8.1. High-Risk Investors. The company faces the risk of money laundering and terrorist financing when accepting investments from clients who may be associated with international criminal networks, terrorist organizations, or those attempting to conceal the source of their funds.
8.2. Opacity in Funding Sources. The company may encounter risk if its investors conceal or withhold information about their sources of income. This could inadvertently involve the fund in a money laundering scheme.
8.3. Investing in Risky Countries. The company may face risk when accepting investments in countries with high levels of corruption, opaque business practices, or countries experiencing economic or political difficulties.
8.4. Uncontrolled Transactions. The company may face risk when accepting transactions from clients who attempt to hide their identity or evade proper scrutiny during transactions.
8.5. Unauthorized Use of the Fund. The company may face risk if its investors utilize the fund to legitimize proceeds obtained from illegal sources or to finance terrorist organizations.
9. Reporting obligations. This section provides policies and procedures for reporting any violations of the AML Policy to the appropriate regulatory authorities, as well as cooperating with any investigations or requests related to money laundering or terrorist financing.
9.1. Internal message. Any suspicion or discovery of a violation of the AML Policy is immediately reported to the designated team responsible for enforcing the AML Policy.
9.2. Investigation. The designated officer in charge interviews the officers who discover questionable transactions for additional information.
9.3. Reporting obligations. This section provides policies and procedures for reporting any violations of the AML Policy to the appropriate regulatory authorities, as well as cooperating with any investigations or requests related to money laundering or terrorist financing.
9.4. Analysis. Based on the information obtained from the interview and any other additional information, the designated responsible officer analyzes the policy violation case and the transaction to determine if there is any suspicious activity.
9.5. Report. If a transaction is determined to be fraudulent in violation of AML policies, the designated responsible officer will promptly report it to the appropriate regulatory authorities in accordance with local jurisdiction, laws and regulations.
9.6. Cooperation. The Company undertakes to cooperate with any investigations or requests related to money laundering or terrorist financing conducted by the relevant regulatory authorities or law enforcement agencies.
9.7. Review and training. The Company conducts regular reviews and trains employees on updated policies and procedures for complying with the AML Policy.
