AML Policy store’s AML Policy has been developed to prevent money laundering and counteracting terrorist financing in accordance with the European AML/CTF Directive and obligations arising therefrom, including the necessity to have adequate systems and controls in order to reduce the risk of using a company to facilitate financial crimes.

Money Laundering

– shall mean the following conduct committed intentionally for the purpose of:

The conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such activity to evade the legal consequences of these actions. The concealment or disguise of the true nature, source, location, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity or from an act of participation in such activity.

The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such activity.

Participation in, association to commit, attempts to commit and aiding. Terrorist financing provides funds for terrorist activities. It may involve funds obtained from legal sources, such as personal donations and profits of businesses and charitable organizations, as well as from illegal sources, such as the drug trade, the smuggling of weapons and other goods, fraud, kidnapping or extortion.

Identification of customer and verification of customer’s identity on the basis of documents, data or information obtained from reliable and independent sources.

Identification of a property user and taking, to a reasonable extent, measures to verify his/her identity to the satisfaction of the institution or person in a manner that they are convinced that they know who the property user is, which in the case of legal persons, trusts and entities of a similar legal form includes taking, to a reasonable extent, measures to understand the ownership structure and customer control.

Obtaining information about the purpose and intended nature of business relations; conducting ongoing activities aimed at ensuring due care in business relations, including meticulous examination of transactions carried out during such relations in order to ensure that the conducted transactions are consistent with the knowledge of a given institution or person about the customer, business profile and risk, which includes, as necessary, sources of funds, as well as ensuring that the documents, data or information held are constantly updated. Conducting employee training on knowledge about money laundering and terrorist financing issues.

Sanctions Policy is forbidden to carry out transactions with entities, companies and countries included the list of entities subject to sanctions.

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