AML POLICY
MICOLNES LIMITED LIABILITY COMPANY
MICOLNES LIMITED LIABILITY COMPANY
MICOLNES LIMITED LIABILITY COMPANY ("SWC-PAY" / "Company"/ «we», «our company») has no tolerance for money laundering, the financing of terrorism or any other form of illicit activity, and is committed to implementing policies, procedures and controls shaped by the best industry practices and the most effective anti-money laundering standards applied in the Republic of Poland and worldwide. These rules apply to, without exception, all employees of the Company, its Board members, officers, contractors, and consultants.
The purpose of this document is to provide the Company's partners, clients, users, contractors, employees, regulators, law enforcement and other concerned stakeholders with a high-level overview of the Company's AML/CTF compliance regime elements and procedures.
By no means this document shall not be read as an entire set of all policies, procedures and controls in place implemented by the Company for prevention of money laundering, financing of terrorism and other forms of illicit activity. In order to protect the assets of our clients and ensure compliance with international GDPR standards, we act exclusively in accordance with the laws on combating money laundering and countering the financing of terrorism. To monitor compliance with legal requirements and FATF recommendations, we have created a compliance department that develops anti-money laundering and Know Your Customer (AML / KYC) procedures that are mandatory for all employees and partners, determining the policy of engagement with any person who is our client.
The Compliance Department is designed to ensure that all Company operations comply with international anti-money laundering standards, and all documents provided by the Client are up-to-date and comply with relevant legal requirements.
The Management Board of the Company is obliged to introduce this Policy together with appendices to all employees upon employment and thereafter as necessary, but not less than once a year.
The provisions of this Policy apply to all business relations and transactions related to clients, including transactions made through agents and upon transfer of economic activities to a third party.
These rules of policy shall be regularly reviewed and supplemented and updated as necessary, but not less than once a year.
The purpose of this document is to provide the Company's partners, clients, users, contractors, employees, regulators, law enforcement and other concerned stakeholders with a high-level overview of the Company's AML/CTF compliance regime elements and procedures.
By no means this document shall not be read as an entire set of all policies, procedures and controls in place implemented by the Company for prevention of money laundering, financing of terrorism and other forms of illicit activity. In order to protect the assets of our clients and ensure compliance with international GDPR standards, we act exclusively in accordance with the laws on combating money laundering and countering the financing of terrorism. To monitor compliance with legal requirements and FATF recommendations, we have created a compliance department that develops anti-money laundering and Know Your Customer (AML / KYC) procedures that are mandatory for all employees and partners, determining the policy of engagement with any person who is our client.
The Compliance Department is designed to ensure that all Company operations comply with international anti-money laundering standards, and all documents provided by the Client are up-to-date and comply with relevant legal requirements.
The Management Board of the Company is obliged to introduce this Policy together with appendices to all employees upon employment and thereafter as necessary, but not less than once a year.
The provisions of this Policy apply to all business relations and transactions related to clients, including transactions made through agents and upon transfer of economic activities to a third party.
These rules of policy shall be regularly reviewed and supplemented and updated as necessary, but not less than once a year.
Risk-Based Approach and Risk Assessment
Company will perform a risk-based due diligence and collect information and documentation on each prospective client in order to assess the risk profile associated. The Company's officers will exercise care, due diligence and good judgement in determining the overall character and nature of all clients. Company conducts its business in accordance with the highest ethical standards and will not enter into business relationships with individuals or entities that may adversely affect Company's reputation and compromise virtual currency industry.
In response to the scale and effect of money laundering, local and international laws, including European Union directives, have been designed to combat money laundering and terrorism financing.
Our AML/CTF Policy covers the following:
• Client Identification & Verification Procedures – we have adequate controls and procedures to ensure we know with whom we are conducting business, commonly referred to as Know Your Customer (KYC), including Enhanced Due Diligence (EDD) measures for clients deemed as higher risk, for example Politically Exposed Persons (PEPs).
• Card Verification – for clients using payment cards, we have card verification procedures.
• Transaction Monitoring & Ongoing Monitoring – we analyse data and transactional patterns as a risk-assessment and suspicion detection tool. The Client guarantees the legal origin, legal ownership and the right to use the Assets transferred to its account.
• In case of the evidence of suspicious transactions at the Client’s account, cash replenishments from untrusted sources and / or any actions with attributes of fraud (including any refunds or cancellation of payments), the Company reserves the right to conduct an internal investigation, to block or close any Personal’s Account, cancel any payment order and to suspend operations on the Accounts before the end of the official investigation. When making the decision the Company is guided by the provisions of the applicable law and FATF recommendations.
• Money Laundering Reporting Officer (MLRO) – we have appointed a MLRO with sufficient level of experience, who has responsibility for oversight of compliance with the relevant legislations, regulations and rules.
• Risk Assessment and Management – we have adopted a risk-based approach to combating money laundering and terrorist financing.
• Record Keeping. The Company is obliged and has the right without obtaining prior consent to share with financial institutions and law enforcement agencies any information about the Client, as required by applicable law, and the Client gives the Company its consent to these actions. In order to comply with this paragraph, the Company holds a records about Client’s transactions during five years at least.
• Employee Due Diligence and Risk Awareness Training – we screen all employees and conduct additional background checks on entrusted employees. We provide training for all relevant employees on an ongoing basis.
The Company’s refuse to perform the operations that from Company’s point of view are considered to be a suspicious, using of preventive measures (such as blocking or closing of an Account) is not the reason for civil liability of the Company for failure to fulfill obligations to the clients.
We are not obliged to inform the Clients or other persons about the measures taken to fulfil the AML/CFT legislation. Also the Company is not obliged to inform Clients or other persons about any suspicions, about the reasons of refuse of execution of a Client’s order, of refuse to open the Account, need for providing Client’s documents, etc.
In response to the scale and effect of money laundering, local and international laws, including European Union directives, have been designed to combat money laundering and terrorism financing.
Our AML/CTF Policy covers the following:
• Client Identification & Verification Procedures – we have adequate controls and procedures to ensure we know with whom we are conducting business, commonly referred to as Know Your Customer (KYC), including Enhanced Due Diligence (EDD) measures for clients deemed as higher risk, for example Politically Exposed Persons (PEPs).
• Card Verification – for clients using payment cards, we have card verification procedures.
• Transaction Monitoring & Ongoing Monitoring – we analyse data and transactional patterns as a risk-assessment and suspicion detection tool. The Client guarantees the legal origin, legal ownership and the right to use the Assets transferred to its account.
• In case of the evidence of suspicious transactions at the Client’s account, cash replenishments from untrusted sources and / or any actions with attributes of fraud (including any refunds or cancellation of payments), the Company reserves the right to conduct an internal investigation, to block or close any Personal’s Account, cancel any payment order and to suspend operations on the Accounts before the end of the official investigation. When making the decision the Company is guided by the provisions of the applicable law and FATF recommendations.
• Money Laundering Reporting Officer (MLRO) – we have appointed a MLRO with sufficient level of experience, who has responsibility for oversight of compliance with the relevant legislations, regulations and rules.
• Risk Assessment and Management – we have adopted a risk-based approach to combating money laundering and terrorist financing.
• Record Keeping. The Company is obliged and has the right without obtaining prior consent to share with financial institutions and law enforcement agencies any information about the Client, as required by applicable law, and the Client gives the Company its consent to these actions. In order to comply with this paragraph, the Company holds a records about Client’s transactions during five years at least.
• Employee Due Diligence and Risk Awareness Training – we screen all employees and conduct additional background checks on entrusted employees. We provide training for all relevant employees on an ongoing basis.
The Company’s refuse to perform the operations that from Company’s point of view are considered to be a suspicious, using of preventive measures (such as blocking or closing of an Account) is not the reason for civil liability of the Company for failure to fulfill obligations to the clients.
We are not obliged to inform the Clients or other persons about the measures taken to fulfil the AML/CFT legislation. Also the Company is not obliged to inform Clients or other persons about any suspicions, about the reasons of refuse of execution of a Client’s order, of refuse to open the Account, need for providing Client’s documents, etc.
CLIENT EVALUATION
Each client of the Company is assessed in accordance with these guidelines.
In the evaluation of the Client, the Company proceeds from the "Know Your Customer" principle and international standards and practices.
When conducting a preliminary background check of a potential Client, the assessment of the risks of money laundering and terrorist financing is based on the Client’s residence, economic and personal activities, legal form, expected volume of transactions and selected services.
In the assessment of a potential Client, his reputation is also taken into account. The following background study is conducted for the client:
-Information about the Client’s personal or economic activities.
-Information on the origin of the Client’s financial resources.
-Information about the actual beneficiary.
-Tracking transactions on the client’s account and, if necessary, asking for documents related to transactions.
-Keeping and protecting the information received and updating regular information and documents.
-The company does not serve or co-operate with the following persons:
1. that are not identified in conformity with law requirements due to the lack of data provided.
2. Who fails to submit the requested documents that are required by law and are necessary for the establishment of the account and the execution of transactions or attempts to circumvent the submission of documents or to submit fewer documents than required.
3. There is a reason to doubt the authenticity of the documents submitted.
4. Who refuses to provide data on the origin of his or her financial means where the provision of such information is required by law.
5. There are grounds for believing that he or she has participated in or contributed to the commission of a terrorist act.
6. Under 18 years of age.
7. about whom information has been gathered accord to which there are grounds for believing that money laundering or terrorist financing may be involved.
8. to whom international sanctions apply.
In the evaluation of the Client, the Company proceeds from the "Know Your Customer" principle and international standards and practices.
When conducting a preliminary background check of a potential Client, the assessment of the risks of money laundering and terrorist financing is based on the Client’s residence, economic and personal activities, legal form, expected volume of transactions and selected services.
In the assessment of a potential Client, his reputation is also taken into account. The following background study is conducted for the client:
-Information about the Client’s personal or economic activities.
-Information on the origin of the Client’s financial resources.
-Information about the actual beneficiary.
-Tracking transactions on the client’s account and, if necessary, asking for documents related to transactions.
-Keeping and protecting the information received and updating regular information and documents.
-The company does not serve or co-operate with the following persons:
1. that are not identified in conformity with law requirements due to the lack of data provided.
2. Who fails to submit the requested documents that are required by law and are necessary for the establishment of the account and the execution of transactions or attempts to circumvent the submission of documents or to submit fewer documents than required.
3. There is a reason to doubt the authenticity of the documents submitted.
4. Who refuses to provide data on the origin of his or her financial means where the provision of such information is required by law.
5. There are grounds for believing that he or she has participated in or contributed to the commission of a terrorist act.
6. Under 18 years of age.
7. about whom information has been gathered accord to which there are grounds for believing that money laundering or terrorist financing may be involved.
8. to whom international sanctions apply.
ASSESSMENT OF RISKS AND DETERMINATION OF THE LEVEL OF APPLIED DUE DILIGENCE MEASURES
In case of making a transaction with a client of the company or establishing a business relationship if the value of the client’s transactions in a calendar month exceeds 15000 euro, regardless of whether the financial liability is fulfilled in a single payment or in the amount of several interrelated payments in a period of up to one month or an equivalent amount in another currency, the degree of risk of money laundering and terrorist financing must be assessed and, accordingly, the appropriate diligence measures chosen and applied.
The following categories must be taken into account when assessing the level of risk of money laundering and terrorist financing:
1. Geographical risk.
2. Client risk.
3.Transaction risk.
Geographic risk is considered to be high when a client or transaction has a known relationship with the following countries or territories:
Countries and territories for which the UN or European Union sanction, embargo or other analogous measure has been implemented. Countries where there are insufficient measures to combat money laundering and terrorist financing. Countries that are undoubtedly known to support terrorism or where there is a high level of corruption. Client risk is considered to be high when the client:
- is a person whose structure, form or relationship with other persons is unusual or systematized in such a way that it is not possible to identify the beneficial owner;
- is a legal person, the majority of whose shares form the bearer’s shares;
- is a legal entity registered in a low-tax area;
- is a national background person, his family member or a close associate;
- Listed on the UN or the European Union list of persons subject to international financial sanctions.
-is a natural or legal person that has, or has previously been, suspected of being involved in money laundering or terrorist financing.
The risk associated with the transaction is considered to be high if:
The transaction is paid by a non-party person.
A transaction is being requested, one of the objectives of which is to hide the actual dealers.
A transaction is requested that does not have a reasonable commercial, economic, fiscal or legal purpose.
The risk of money laundering or terrorist financing is considered to be high if there is any reason to suspect that a client or client transaction may be related to money laundering or terrorist financing.
The following categories must be taken into account when assessing the level of risk of money laundering and terrorist financing:
1. Geographical risk.
2. Client risk.
3.Transaction risk.
Geographic risk is considered to be high when a client or transaction has a known relationship with the following countries or territories:
Countries and territories for which the UN or European Union sanction, embargo or other analogous measure has been implemented. Countries where there are insufficient measures to combat money laundering and terrorist financing. Countries that are undoubtedly known to support terrorism or where there is a high level of corruption. Client risk is considered to be high when the client:
- is a person whose structure, form or relationship with other persons is unusual or systematized in such a way that it is not possible to identify the beneficial owner;
- is a legal person, the majority of whose shares form the bearer’s shares;
- is a legal entity registered in a low-tax area;
- is a national background person, his family member or a close associate;
- Listed on the UN or the European Union list of persons subject to international financial sanctions.
-is a natural or legal person that has, or has previously been, suspected of being involved in money laundering or terrorist financing.
The risk associated with the transaction is considered to be high if:
The transaction is paid by a non-party person.
A transaction is being requested, one of the objectives of which is to hide the actual dealers.
A transaction is requested that does not have a reasonable commercial, economic, fiscal or legal purpose.
The risk of money laundering or terrorist financing is considered to be high if there is any reason to suspect that a client or client transaction may be related to money laundering or terrorist financing.
IDENTITY OF PERSONALITY IN EXECUTION OF TRANSACTIONS AND ESTABLISHING CLIENTS RELATIONS
An employee of Company shall apply the following rules of procedure each time before the client makes a transaction or establishes a business relationship if the value of the client’s transactions in a calendar month less than 15000 euros or equivalent in another currency, regardless of whether the obligation is fulfilled in a single payment or in a series of interrelated or multiple interconnected payments: The Client is identified on the basis of an identity document whose personal data and photocopy of the page are kept in the Company’s clients database. Identity is determined on the basis of the following documents: on the basis of the passport, ID card, alien’s passport, residence permit or driving license, travel document issued in a foreign country (in a Member State of the European Union and in a third country)
The following data are recorded and stored for a natural person:
1. Name, representative’s name.
2. Personal code, or, in its absence, the date and place of birth.
3. Name, number, date of issue and name of the issuing authority for the document used to identify and verify the person.
4. Residential address.
5. Person’s occupation or field of activity.
If a person is a natural person in another Contracting Party to the European Economic Area or third country, in addition to the data above, the following data shall be recorded:
1. Whether a person performs or has performed essential functions of public authority.
2. Whether he is a close associate or a family member who performs important functions of public authority.
If a person is a representative of a foreign legal person, he or she must submit a document approved notarially or in the equal manner, certifying his or her authority, which is legalized or approved by a certificate replacing legalization, unless otherwise provided by an international agreement.
A client of a legal nature is identified and stored on the basis of the following information:
1) the business name or the name of the legal entity;
2) the registry code or registration number and time;
3) the name of the director or the names of the members of the management board or other body replacing it and their powers in representing a legal person;
4) the data of the means of communication of a legal person.
The identity of a legal entity registered in foreign country is identified by an extract from the relevant register.
The identity of a foreign legal person is established on the basis of an extract from the relevant register or a copy of the certificate of registration or equivalent, issued by the competent authority or body not earlier than six months before it is submitted.
The document submitted to identify a person must at least include:
1. Business name, or name, location and address of legal entity.
2. Registry code or registration number.
3. Date of issue and name of the issuing authority.
4. The name of the director or names of the members of the management board or members of other bodies replacing it, and their powers in representing a legal person.
5. Field of activity of a legal person.
6. Means of communication: telephone and e-mail address.
7. The data of beneficial owners of a legal entity.
If a legal entity can be associated with a national background person from anot. If a legal entity can be associated with a national background person from another state of the EEA Agreement or a third country, the following information must also be recorded:
1. Whether a person performs or has performed essential functions of public authority.
2. Whether he is a close associate or a family member who performs important functions of public authority.
Company shall not enter into a contract and shall not perform a transaction:
- with a person who refuses to provide the information and documents specified in this section as well as with a person who is suspected of being a shadow person.
- If the client fails to submit the required documents and relevant information, or if, on the basis of the documents submitted, it is suspected that there may be money laundering or terrorist financing or there is a person subject to an international sanction.
In mediating a transaction between multiple clients, the employee of the company is required to verify the identity of each person participating in the transaction and verify the information provided.
The following data are recorded and stored for a natural person:
1. Name, representative’s name.
2. Personal code, or, in its absence, the date and place of birth.
3. Name, number, date of issue and name of the issuing authority for the document used to identify and verify the person.
4. Residential address.
5. Person’s occupation or field of activity.
If a person is a natural person in another Contracting Party to the European Economic Area or third country, in addition to the data above, the following data shall be recorded:
1. Whether a person performs or has performed essential functions of public authority.
2. Whether he is a close associate or a family member who performs important functions of public authority.
If a person is a representative of a foreign legal person, he or she must submit a document approved notarially or in the equal manner, certifying his or her authority, which is legalized or approved by a certificate replacing legalization, unless otherwise provided by an international agreement.
A client of a legal nature is identified and stored on the basis of the following information:
1) the business name or the name of the legal entity;
2) the registry code or registration number and time;
3) the name of the director or the names of the members of the management board or other body replacing it and their powers in representing a legal person;
4) the data of the means of communication of a legal person.
The identity of a legal entity registered in foreign country is identified by an extract from the relevant register.
The identity of a foreign legal person is established on the basis of an extract from the relevant register or a copy of the certificate of registration or equivalent, issued by the competent authority or body not earlier than six months before it is submitted.
The document submitted to identify a person must at least include:
1. Business name, or name, location and address of legal entity.
2. Registry code or registration number.
3. Date of issue and name of the issuing authority.
4. The name of the director or names of the members of the management board or members of other bodies replacing it, and their powers in representing a legal person.
5. Field of activity of a legal person.
6. Means of communication: telephone and e-mail address.
7. The data of beneficial owners of a legal entity.
If a legal entity can be associated with a national background person from anot. If a legal entity can be associated with a national background person from another state of the EEA Agreement or a third country, the following information must also be recorded:
1. Whether a person performs or has performed essential functions of public authority.
2. Whether he is a close associate or a family member who performs important functions of public authority.
Company shall not enter into a contract and shall not perform a transaction:
- with a person who refuses to provide the information and documents specified in this section as well as with a person who is suspected of being a shadow person.
- If the client fails to submit the required documents and relevant information, or if, on the basis of the documents submitted, it is suspected that there may be money laundering or terrorist financing or there is a person subject to an international sanction.
In mediating a transaction between multiple clients, the employee of the company is required to verify the identity of each person participating in the transaction and verify the information provided.
IMPLEMENTATION OF DUE DILIGENCE MEASURES
Greater attention should be paid to the activities and circumstances of a person or client involved in a transaction that refers to money laundering or terrorist financing, or which are likely to be linked to money laundering or terrorist financing, including complex, high value and unusual transactions that do not have a reasonable economic purpose.
There are following applicable diligence measures:
1. Identification of the person who participates in a client or occasional transaction, and verification of the information provided, and the information obtained from a reliable and independent source, including eidentification and e-transactions trust services.
2. Identification and verification of the identity and right of representation of a representative of a natural or legal person.
3. Identification of the beneficial owner, including the collection of information on the ownership and control structure of a legal entity, trust company, partnership or other such contractual legal entity, information supplied in the pre-contractual negotiations or other reliable information obtained from an independent source;
4. Obtaining information about the client's business relationship and the purpose and nature of the transaction.
5. Continuous monitoring of the client business relationship, including tracking transactions conducted during a business relationship, regular checking of the data used to identify the person, updating relevant documents, data and information, and, if necessary, identifying the source and origin of the funds used in the transaction.
Increased attention must be paid to the activities and circumstances of a person or client involved in the transaction if a person engaged in an economic or professional transaction or an official act, a person using the professional service, a client or a beneficial owner thereof is a national background, a family member of a national background or a close associate of a national background person.
„Family member” includes the following persons:
(a) a person considered to be a spouse of a national background or a person deemed equivalent to a spouse;
(b) children of a national background and their spouses or persons deemed equivalent to their spouses;
(c) parents of a national background.
“Person considered as a close associate”:
(a) a natural person who is known to be a joint owner of a legal person or legal entity, who is deemed a beneficiary owner together with a national background or who has close business relations with a national background;
(b) a natural person who is the sole beneficial owner of a legal entity or legal unit known to be actually established for the benefit of a national background. receiving an approval of the senior management for creation or continuation of a business relationship with this person.
Applicable diligence measures are:
1. receiving an approval of the senior management for creation or continuation of a business relationship with this person;
2. the origin of the wealth of a person and the sources of funds that are used in business or occasional transactions, and the monitoring of this business relationship in an enhanced manner.
3. If a national background person no longer fulfills the significant public tasks assigned to him, Company must, within a period of 12 months least, take into account the risks that continue to be associated with that person and implement appropriate and risk-sensitive measures as long as it is certain that the risks inherent to the person of national background no longer exist.
In the application of due diligence measures, the facts to be determined are usually determined on the basis of the original documents submitted by the client. If the original document cannot be obtained, the notarised or officially certified documents, i.e. documents approved by the lawyer, may be used. If this is not reasonable considering the level of risk, a copy of the original document must be certified with the corresponding stamp and / or issuer’s signature and may be transmitted electronically (in the reproducible in writing form). A copy may not be relied on if there is doubt as to its originality.
The above-mentioned due diligence measures must be applied before the establishment of a business relationship or transaction.
The identity of the client, of a person taking part in the transaction and the beneficial owner can be identified and the information checked during the establishment of the business relationship or transaction if this is necessary to ensure that the normal course of business is not interrupted or if the risk of money laundering or terrorist financing is low. In this case, due diligence measures should be discontinued as soon as possible after the first contact has been established and before the binding operations are carried out.
If necessary, it is necessary to require the confirmation of the information and documents submitted by the person or client involved in the economic or professional activity or official action with the signature confirming the accuracy of the information and documents submitted for the application of the diligence measures.
There are following applicable diligence measures:
1. Identification of the person who participates in a client or occasional transaction, and verification of the information provided, and the information obtained from a reliable and independent source, including eidentification and e-transactions trust services.
2. Identification and verification of the identity and right of representation of a representative of a natural or legal person.
3. Identification of the beneficial owner, including the collection of information on the ownership and control structure of a legal entity, trust company, partnership or other such contractual legal entity, information supplied in the pre-contractual negotiations or other reliable information obtained from an independent source;
4. Obtaining information about the client's business relationship and the purpose and nature of the transaction.
5. Continuous monitoring of the client business relationship, including tracking transactions conducted during a business relationship, regular checking of the data used to identify the person, updating relevant documents, data and information, and, if necessary, identifying the source and origin of the funds used in the transaction.
Increased attention must be paid to the activities and circumstances of a person or client involved in the transaction if a person engaged in an economic or professional transaction or an official act, a person using the professional service, a client or a beneficial owner thereof is a national background, a family member of a national background or a close associate of a national background person.
„Family member” includes the following persons:
(a) a person considered to be a spouse of a national background or a person deemed equivalent to a spouse;
(b) children of a national background and their spouses or persons deemed equivalent to their spouses;
(c) parents of a national background.
“Person considered as a close associate”:
(a) a natural person who is known to be a joint owner of a legal person or legal entity, who is deemed a beneficiary owner together with a national background or who has close business relations with a national background;
(b) a natural person who is the sole beneficial owner of a legal entity or legal unit known to be actually established for the benefit of a national background. receiving an approval of the senior management for creation or continuation of a business relationship with this person.
Applicable diligence measures are:
1. receiving an approval of the senior management for creation or continuation of a business relationship with this person;
2. the origin of the wealth of a person and the sources of funds that are used in business or occasional transactions, and the monitoring of this business relationship in an enhanced manner.
3. If a national background person no longer fulfills the significant public tasks assigned to him, Company must, within a period of 12 months least, take into account the risks that continue to be associated with that person and implement appropriate and risk-sensitive measures as long as it is certain that the risks inherent to the person of national background no longer exist.
In the application of due diligence measures, the facts to be determined are usually determined on the basis of the original documents submitted by the client. If the original document cannot be obtained, the notarised or officially certified documents, i.e. documents approved by the lawyer, may be used. If this is not reasonable considering the level of risk, a copy of the original document must be certified with the corresponding stamp and / or issuer’s signature and may be transmitted electronically (in the reproducible in writing form). A copy may not be relied on if there is doubt as to its originality.
The above-mentioned due diligence measures must be applied before the establishment of a business relationship or transaction.
The identity of the client, of a person taking part in the transaction and the beneficial owner can be identified and the information checked during the establishment of the business relationship or transaction if this is necessary to ensure that the normal course of business is not interrupted or if the risk of money laundering or terrorist financing is low. In this case, due diligence measures should be discontinued as soon as possible after the first contact has been established and before the binding operations are carried out.
If necessary, it is necessary to require the confirmation of the information and documents submitted by the person or client involved in the economic or professional activity or official action with the signature confirming the accuracy of the information and documents submitted for the application of the diligence measures.
MLRO Officer
The management board of the Company shall appoint Special Officer, who acts as a contact person of the FIUE and performs AML/CTF duties and obligations of the Company. MLRO reports directly to the management board and has the competence, means and access to relevant information across all the structural units of the Company.
MLRO should have the relevant education, professional suitability, the abilities, personal qualities, experience and impeccable reputation required for performance of the duties listed below.
MLRO implements and has oversight of and is responsible for the following matters:
(a) the day-to-day operations for compliance by the Relevant Person with its Anti-Money Laundering policies, procedures, systems and controls;
(b) acting as the point of contact to receive notifications from the Relevant Person's Employees;
(c) taking appropriate action under following receipt of a notification from an Employee;
(d) making, in accordance with Federal AML Legislation, Suspicious Activity Reports;
(e) acting as the point of contact within the Relevant Person for competent authorities and the Regulator regarding money laundering issues;
(f) responding promptly to any request for information made by competent authorities or the Regulator;
(g) receiving and acting upon any relevant findings, recommendations, guidance, directives, resolutions, Sanctions, notices or other conclusions;
(h) establishing and maintaining an appropriate money laundering training program and adequate awareness arrangements.
MLRO jointly with AML officer organize the collection and analysis of information referring to unusual transactions or transactions or circumstances suspected of money laundering or terrorist financing, which have become evident in the activities of the Company; report to the FIUE in the event of suspicion of money laundering or terrorist financing; periodically submit of written statements on compliance with the requirements arising from the Act to the management board of the Company and perform other duties and obligations related to compliance with the requirements of the Act.
MLRO should have the relevant education, professional suitability, the abilities, personal qualities, experience and impeccable reputation required for performance of the duties listed below.
MLRO implements and has oversight of and is responsible for the following matters:
(a) the day-to-day operations for compliance by the Relevant Person with its Anti-Money Laundering policies, procedures, systems and controls;
(b) acting as the point of contact to receive notifications from the Relevant Person's Employees;
(c) taking appropriate action under following receipt of a notification from an Employee;
(d) making, in accordance with Federal AML Legislation, Suspicious Activity Reports;
(e) acting as the point of contact within the Relevant Person for competent authorities and the Regulator regarding money laundering issues;
(f) responding promptly to any request for information made by competent authorities or the Regulator;
(g) receiving and acting upon any relevant findings, recommendations, guidance, directives, resolutions, Sanctions, notices or other conclusions;
(h) establishing and maintaining an appropriate money laundering training program and adequate awareness arrangements.
MLRO jointly with AML officer organize the collection and analysis of information referring to unusual transactions or transactions or circumstances suspected of money laundering or terrorist financing, which have become evident in the activities of the Company; report to the FIUE in the event of suspicion of money laundering or terrorist financing; periodically submit of written statements on compliance with the requirements arising from the Act to the management board of the Company and perform other duties and obligations related to compliance with the requirements of the Act.
TRAINING OF EMPLOYEES
Responsibility for training of the employees of the company on the prevention of money laundering and terrorist financing and compliance with international sanctions rests with the Contact person or employee appointed by the management board or a specialist in the field (mlro).
Training is carried out as needed, but not less than once a year. The employee confirms participation in the training with his/her signature. The contact person has the right to make proposals to the management board of the institution regarding the educators.
Training is carried out as needed, but not less than once a year. The employee confirms participation in the training with his/her signature. The contact person has the right to make proposals to the management board of the institution regarding the educators.
CONTROL
The compliance of the legislation for compliance with the law concerning AML procedure is established on the basis thereof with the employees of Company is monitored and controlled by the Management Board of Company.
INTERNAL CONTROL AND RESPONSIBLE PERSONS
The compliance with the requirements for the prevention of money laundering and terrorist financing by the employees of the Company is monitored and controlled by the Management Board of the Company.
The risk assessment and the identification and control of the client’s personal data is carried out by a specifically trained employee of the Company.
The control over the client’s activities and operations (i.e., analysis, monitoring, etc.) is performed by a specifically trained employee of the Company.
Confirmed, 2025 year: Evgeniy Kudryashov
Management board member
The risk assessment and the identification and control of the client’s personal data is carried out by a specifically trained employee of the Company.
The control over the client’s activities and operations (i.e., analysis, monitoring, etc.) is performed by a specifically trained employee of the Company.
Confirmed, 2025 year: Evgeniy Kudryashov
Management board member
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