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