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:
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:
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:
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:
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:
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:
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:
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.