ANTI-MONEY LAUNDERING POLICY
Vs 1.0 November 2016
The purpose of this policy is to provide guidance on the Anti-Money Laundering and Know your
Client Policy which is followed by the Company in order to achieve full compliance with the
relevant anti-money laundering legislation.
To prevent money laundering, the Company neither accepts nor pays cash under any circumstances.
The company reserves the right to suspend any clients operation, which can be regarded as illegal
or, may be related to money laundering in the opinion of the staff.
The Company will make sure that it is dealing with a real person or legal entity. The AML policy is
being fulfilled by means of the following:
• know your customer policy and due diligence
• monitoring of client activity
• record keeping
Know Your Customer and Due Diligence
Because of the companys commitment to the AML and KYC policies, each client of the company has to
finish a verification procedure. Client and beneficial owner identification must occur before the
establishment of a business relationship, given that the Company prohibits any client’s transaction or trade
before the identification procedure is completed.
During the process of registration, each client provides personal information, specifically: full name; date of
birth; origin; complete address, including phone number and city code. A client sends the following
documents (in case the documents are written in non-Latin characters: to avoid any delays in the verification
process, it is necessary to provide a notarized translation of the document in English) because of the
requirements of KYC and to confirm the indicated information:
1. Clear copy of Passport with photograph included;
2. A recent proof of home address in the person’s name.
All documents/certificates must not be more than 6 months old
3. Bank account details for settlement purposes
The Company may request notarized copies of the originals and in certain circumstances may request further
proof identification and documentation.
Monitoring of client activity
The Company continues to monitor the activity of every client to identify and prevent any suspicious
transactions. A suspicious transaction will often be one which is inconsistent with a the client’s known,
legitimate business or personal activities or with the normal business of the specific account, or in general
with the economic profile that the Company has created for the client.. The Company has implemented the
system of monitoring the named transactions (both automatic and, if needed, manual) to prevent using the
companys services by criminals.
Deposit and withdrawal requirements
All the clients operations to deposit and withdraw funds have the following requirement:
In case of bank transfer or transfer from a bank card, the name, indicated during the registration must
match the name of the owner of the account/bank card.
For client due diligence, a copy of the references of the evidence is required, for a period of at least 5 years
after the business relationship with the client has ended.