AML & KYC Policy
1. General Provisions
1.1. This AML policy aligns with the latest FATF, OECD, global anti-money laundering standards, and relevant domestic AML legislation.
1.2. The policy dictates internal rules for the Company, focusing on checking and disclosing documentation and information related to controlled operations and financial transactions associated with money laundering or terrorism financing.
1.3. It organizes activities to prevent money laundering and terrorism financing, establishing obligations and procedures for internal control by employees.
2. Organizational Basis for Control Methods
2.1. A dedicated group, including a board member, head accountant, and legal department head, ensures effective policy implementation based on client volume and associated risk levels.
2.2. Subsidiaries are accountable to the authorized group for handling suspicious transactions while corresponding company units manage initial client identification.
3. Implementation of Control Methods
3.1. Control methods identify clients and assess risks during the initiation and continuation of commercial relationships, specifically for money laundering prevention.
3.2. Data is collected and processed solely for purposes outlined in this policy, with no unauthorized use or third-party disclosure unless required by law.
4. Client and Associated Persons Identification Program
4.1. Initial client identification relies on provided documents, verifying necessary information for physical and legal persons, including state official status.
4.2. Information is cross-referenced with official sources and verified through public registries or inquiries to state authorities.
4.3. Only an authorized legal representative may register a legal entity, providing sufficient documentation of their authority.
5. Risk Evaluation
5.1. Clients and planned transactions undergo risk evaluation for money laundering and terrorism financing.
5.2. Clients are assigned risk statuses based on assessed risk factors, and high-risk cases may lead to denial of cooperation and services.
6. Commercial Relationship with the Client
6.1. Any commercial relationship is established after the client agrees to adhere to the AML policy.
6.2. If a representative is involved, the Company ensures direct contact between the client and the representative.
7. Actions in Case of Suspicions and Information Obligation
7.1. Suspicions of transactions connected to money laundering or terrorism financing halt further cooperation.
7.2. Transaction denial may be delayed if it could harm the client, with immediate reporting to the Financial Inspection.
8. Correspondence Exchange
8.1. Correspondence exchange with third parties, including banks, is initiated if deemed necessary by management, formalized with a two-way agreement.
8.2. The exchange includes details of the control methods used.
9. Information Recording Program
9.1. Transaction employees must document all transaction specifics as per the information recording program.
10. Transaction Denial Program
10.1. Clients not providing the required documentation may face transaction denial, with the possibility of reversal upon providing necessary information and documents.
11. Company Employees Training Program
11.1. Training programs ensure employees comply with AML legislation and terrorism financing prevention, providing instructions within one month of employment.
12. Internal Control Review Program
12.1. The internal control review program ensures employee compliance with legislation and internal rules, maintaining control in income legalization and terrorism financing prevention.
13. Document Maintenance Program
13.1. client identification and cooperation initiation documents are archived for at least five years, including those reported to state authorities.