AML policy

Anti-Money Laundering & Counter-Terrorism Financing Policy (“AML/CTF Policy”) sets out the processes and controls to help us prevent, identify, manage and mitigate risks of us being involved in any kind of illegal activity, in particular money laundering.

Money laundering is the process of hiding or disguising the source of illegally obtained (dirty) funds to make them appear legitimate (clean), for example, by filtering the money through the financial system. As such, companies that offer financial services, like ours, are specifically targeted by criminals.

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:

  • Customer Identification & Verification Procedures – we have adequate controls and procedures to ensure we know with whom we are conducting business (CDD), commonly referred to as Know Your Customer (KYC), including Enhanced Due Diligence (EDD) measures for customers deemed as higher risk.
  • Ongoing due diligence (ODD) is performed according to the generated risk level during Customer risk assessment.
  • Transaction Monitoring & Ongoing Monitoring – we analyse data and transactional patterns as a risk-assessment and suspicion detection tool.
  • Money Laundering Reporting Officer (MLRO) – we have appointed a MLRO with sufficient level of seniority, who has responsibility for oversight of compliance with the relevant legislations, regulations, rules and industry guidance.
  • Risk Assessment and Management – we have adopted a risk-based approach to combating money laundering and terrorist financing. We achieve this by accurately measuring our risk profile, balancing it with the need to optimise financial growth opportunities, and implementing processes and controls that commensurate with identified risks. This allows us to allocate resources in the most efficient ways.
  • Record Keeping – we maintain and keep appropriate records for legally prescribed periods;
  • Suspicious Reporting – we report suspicious activity to the relevant law enforcement authorities.
  • Sanctions Policy – we screen against the United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions we operate;
  • 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.

 Does not establish or maintain a business relationship with the following:

  • Customers including Beneficial Ownership (BO) who are included in one or more of the Sanction lists;
  • Customers including BO who fail to provide evidence of their identity or give rise to a suspicion that the information provided is false;
  • Customers, which any one of the responsible persons (BO, director, representative) is politically exposed person (PEP). Family members and close associates are also considered to be PEPs;
  • Companies that are issuing bearer shares, companies and entities owned by bearer share companies (defined as over 20% ownership interest) are prohibited;
  • We might as well establish a list of blacklisted virtual wallet addresses with whom business relationships shall not be established or maintained.

Also we are not working with customers who are resident or incorporated in countries:

  • EU High Risk Third Countries;
  • FATF Black List Countries;
  • EU Tax Haven Countries;
  • Highly Corrupt Countries;
  • High Global Terrorism Index Countries;
  • Russia Country;
  • Belarus Country;
  • Other internal list.