1. Basic principles of activity

1.1. The rules establish a list of actions that prevent the possibility of money laundering, the development of terrorism, and also call for compliance with the sanctions established at the international level. With their help, Clients" transactions are checked with regard to such risks that are associated with money laundering, the development of terrorism, identification is provided, the necessary reporting is drawn up in the presence of a risk that is determined by the Company. AML / KYC policy is used when resolving problems with finances and ongoing transactions.

1.2. The basis for drawing up the rules is the provisions of the legislation dealing with combating money laundering and international regulations on sanctions.

2. Implementation of due diligence actions

2.1. Based on the results obtained after conducting an international risk assessment, as well as the rules for assessing risks in the country, the company determines and applies due diligence actions.

2.2. The competence of authorized persons is to control the circumstances that may be associated with the financing of terrorist activities and money laundering.

2.3. The company applies different types of KYC / AML measures: ordinary, simplified, extended. It depends on what level of risk the Client bears, if there is a business relationship, whether it will be established. To continuously monitor business relationships, the company continuously applies KYC / AML measures.

2.4. When implementing KYC / AML measures, the following occurs:

  • The client is identified, his identity is verified. For this, independent external sources and documents are used.
  • The Client"s representative is identified, his right to exercise representation is checked.
  • The Beneficial owner of the Client is identified.
  • Information about the purpose of the business relationship is evaluated.
  • Permanent KYC / AML is carried out in the Client"s business. This allows you to understand whether the company has correct information about the Client.
  • Information is received as to whether the Client is a PEP (family member, close employee).
  • Information is received from third parties (for example, from authorized bodies).

2.5. The company has the right to establish the source of the Client"s income.

2.6. The fulfillment of KYC / AML obligations by the Company (or another party authorized by the Company) can be carried out using:

  • requesting the necessary documentation of identity confirmation in order to identify the Client, as well as his representatives;
  • requesting the necessary documentation to confirm the activities of the Client, as well as that his source of income is legal;
  • requesting information about beneficial owners, if it is a legal entity;
  • reviewing the Client"s possible risks, choosing the necessary KYC / AML measures, assessing the likelihood that the Client may pose a risk to the company due to involvement in the process of money laundering and the development of terrorism;
  • re-identification of the Client or his representative in case of doubt as to whether the information that was received initially is correct.

2.7. Monitoring of Clients based on the applied KYC / AML measures allows to realize the main goal of the Company Policy. Business relationship monitoring includes:

  • maintaining the relevance of the documentation, information that was obtained during the implementation of KYC / AML measures;
  • distinguishing among other such actions of the Client that may lead to money laundering, the development of terrorism, and other activities of a criminal nature;
  • highlighting among other such actions of the Client that may lead to money laundering, the development of terrorism, and other activities of a criminal nature.

2.8. The company"s employees evaluate the essence and goals of the activities that the Client is engaged in. This is necessary in order to identify the presence in it of such a direction, which is associated with terrorism, money laundering. The result of the work carried out is a correct understanding of the essence, purpose of the Client"s activities, the level of risk that characterizes the business Client.

3. Definition of personality

3.1. By implementing KYC / AML measures, the Company has the right to identify:

  • Client (can be an individual or a legal entity);
  • a representative of the Client (an individual acting on behalf of the Client);
  • the beneficial owner of the Client;
  • PEP (if it is or is associated with a Client);
  • source of profit;
  • information that will be sufficient for the Company (for example, clarifying documents from representatives of the authorities).

3.2. Documentation used in the identification process

3.2.1. If the Client is an individual or his representative, then identification is carried out using:

  • personal identification card, which includes an identity card, electronic resident card or residence permit card);
  • passport (including diplomatic);
  • a travel card that was obtained in another country.

3.2.2. The representative copies a page of an identity document with personal data and a photo.

3.2.3. Also, for the Representative, an addition to the main document is such documentation, which establishes the right to represent the interests of the Client.

3.2.4. A legal entity and its passive legal capacity are identified and verified using:

  • An extract that is made from the registration document of the commercial register. This is true for a legal entity and branches of foreign companies that are registered in the Marshall Islands.
  • An extract that is made from a registering document or other similar documentation issued by an authorized structure 6 months before the submission, but not earlier than this period. This is true for a legal entity in another country.

4. Assessment of risks and actions taken

4.1. The representative is engaged in determining the existing risk profile of the Client, taking into account the information received by him in accordance with the Rules established in the company.

4.2. The company classifies risks into the following types:

  • normal;
  • medium;
  • high.

4.3. The competence of the Company is to apply different combinations of AML / KYC measures, taking into account the type of risk of the Client, as well as the risk-based method used for each Client.

4.4. If the Company detects suspicious transactions on the part of the Client, then on the basis of the applicable legislation and international regulations, it must notify the authorized structures about the Client"s transactions that arouse suspicion, without notifying and approving the Client.

4.5. The Company is responsible for periodically checking with the lists of individuals and entities suspected of terrorism, published by local and international authorities. It may also include countries with high-risk sanctions that do not provide an adequate level of anti-money laundering.

5. Conditions accepted by the Client

5.1. Cooperation with the Company means that the Client understands its Policy, he will carry out operations taking into account full compliance with all the prescriptions set forth in it, as well as the laws and other regulations on the basis of which the Client"s activities in the Company are carried out.

5.2. The client is responsible for his actions, non-compliance with the legislation in the area referred to in the Policy.