AML Policy

What is AML Policy?

Anti-money laundering or AML is a term that is mainly used in the financial and legal sectors to describe the legal measures that require financial institutions and other regulated organizations to prevent, identify and report on activities for money laundering. Anti-Money Laundering (AML) is a set of procedures, laws and regulations aimed at ending the practice of generating income through unlawful acts.

The AML policy of the Company implies all expediently established procedures related to the prevention of money laundering, terrorist financing and other types of illegal activities. The company has prepared the principles of AML Policy to ensure the highest possible voluntary compliance with national and international AML standards, and it will be regularly reviewed and updated to ensure appropriate policy and internal control.

In order to help the government to fight the financing of terrorism and money laundering, we need to receive and register information and documents that serve to confirm the client’s identity or provide additional information on the client. This information may be requested when opening an account or during periodic reviews of existing clients.

AML Policy of the company includes:
• - An anti-money laundering specialist;

• - The internal control system;
• - Customer due diligence;
• - Keeping records;
Anti-Money Laundering Specialist

The duties of an anti-money laundering specialist include:
• - Monitoring of the company’s compliance with AML obligations;
• - Monitoring and control of client’s trading activity;
• - Monitoring of client’s deposits and their withdrawals;
• - Supervision of communication and training of employees;
The anti-money laundering specialist shall also ensure that the company maintains and stores all the records required by the AML Policy and ensure that suspicious actions are reported to the appropriate law enforcement authorities.

Internal Control
The AML Policy of the company was approved in accordance with the established procedure by the Board of Directors in order to monitor compliance with applicable laws and standards in the field of AML.
The company shall carry out a risk assessment associated with the activities of the client, based on:
• - The sufficiency and adequacy of identity documents provided by the client;

• - Methods and other information on deposit replenishment and withdrawal of moneys;
• - Instructions distributed by various governmental and intergovernmental organizations;
Customer Due Diligence
Customer due diligence (“CDD”) is the one of the international standards for preventing illegal activities. According to the CDD, the Company establishes its own verification procedures as part of anti-money laundering policy standards.

The company may collect the following information¹ according to the CDD:
• - Information on individual clients.
Name; Date of Birth; E-mail address; phone number and address of residence; photo; copies or certified copies of any original documents;

• - Information on corporate clients.
Company’s name; name, contact information, photo and copy of original documents of the authorized representative, a certified copy of the certificate of incorporation/registration (as the case may be); memorandum and articles of association/ partnership agreement (as applicable); decision of the Board of Directors/ other consent documents authorizing the representative selected in order to carry out transactions on the website;

In addition to the foregoing, the Company may reserve the right to confirm the client’s identity with uncertificated methods or using both methods. The Company may also use uncertificated methods in the event that there are some doubts about the authenticity of the client’s identity. The Company may use the following uncertificated methods to verify identity:

• - E-mail authentication;

• - Phone number authentication;

• - Client’s location confirmation using, inter alia, the client’s IP address;

All this can be done automatically or manually.
If the Company believes that any information received from the client, under the terms of this agreement is:
• - Inadequate or incomplete;
• - Inaccurate or misleading;
• - Leading to the inability to easily verify authenticity;
• - It is on the sanctions list;
In this case, the Company may, at its own discretion, refuse to register a new account, suspend the service of the client’s account after providing proper notification, or refuse to process any transactions on the Website in the event that the Company cannot verify any information because of the client’s refusal to cooperate, or if such transactions may have a significant adverse effect on the Company for violation of any applicable laws or best practices.

¹Personal data is processed in such a way as to ensure proper protection of personal data, including protection against unauthorized or illegal processing, as well as against accidental loss, destruction or damage using appropriate technical or organizational measures (“principle of integrity and confidentiality”).

Control and Monitoring
The purpose of control and monitoring is to protect the Company from risks and to constantly monitor the process of the Company’s operations in accordance with national and international AML standards. Control and monitoring operations are carried out by an anti-money laundering specialist.

Monitoring and control activities include:

• - Monitoring and control of clients and transactions belonging to the high-risk group;

• - Monitoring and control of complex and unusual transactions;
• - Control, through the sampling method, over the fact that transactions do not exceed the established limit corresponding to the client’s risk profile;
• - Control of all transactions through manual screening and the use of software algorithms to quickly identify various suspicious actions;

• - Control, addition and updating of information and documents on the client;
In addition, the Company can regularly monitor, both through manual screening and using software algorithms, all transactions in order to quickly identify any suspicious actions. The Company may also cancel all transactions in which any suspicious (fraudulent) activity has been identified.

In the event that any suspicious (fraudulent) actions are detected, the Company reserves the right to take appropriate actions without prior notice to the client, which includes, but is not limited to:

• - Blocking of the client’s account;
• - Restriction and/or blocking of further access to the website;
• - Cancellation of all replenishment/ withdrawal transactions with which suspicious (fraudulent) activities were identified;
• - Notifying the relevant executive authorities on the suspicious actions of any client;

Keeping Records
In accordance with applicable AML laws and standards, the Company shall be required to retain and protect the following information and/or data:
• - Records of all transactions made by the client for a period of at least 5 (five) years from the date of each transaction;
• - Records of all suspicious transactions, regardless of whether they are performed or completed, within at least 10 (ten) years, including (but not limited to) information on the date of transfer;

• - Clients’ personal information (including, but not limited to the original documents submitted in accordance with the clause “Customer Due Diligence” described above), in the course of business and for a period of at least 5 (five) years from the date of termination of such a client;

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