Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy
1. General Policy
- The Company prohibits and actively works to prevent money laundering and activities that fund terrorism or other criminal actions. All employees and affiliates are required to uphold these standards to prevent the misuse of Company's services for illegal financial activities.
2. Definition of Money Laundering
- Money laundering involves actions designed to disguise the origins of illegally obtained money, making it appear as though it comes from legitimate sources.
3. Money Laundering Stages
- Placement: Cash from criminal activities enters the financial system.
- Layering: The funds are transferred to other accounts or institutions to further obscure their origins.
- Integration: The funds are reintroduced into the economy, used to purchase legitimate assets or fund additional activities.
4. Employee Responsibilities
- Employees involved in Company services are expected to know and follow applicable laws and regulations related to money laundering prevention.
5. AML Compliance Program
- The Company has established an ongoing program to ensure compliance with relevant laws, minimize exposure to money laundering, and coordinate regulatory requirements across all business units.
6. Affiliate Compliance
- Each Company affiliate must adhere to AML and Know Your Customer (KYC) policies.
7. Documentation Retention
- All identification documents and service records are retained for the minimum period required by local law.
8. Employee Training
- New employees receive anti-money laundering training as part of the onboarding process. Annual AML and KYC training is required for applicable employees.
9. Client Obligations
- Clients must comply with laws regarding anti-money laundering, fraud prevention, and illegal operations.
- Clients must ensure that funds transferred to their account come from legitimate sources.
10. Know Your Customer (KYC) and AML Checks
- The Company reserves the right to conduct KYC and AML/CTF checks on Clients to comply with regulations and prevent financial crimes.
- The Client is required to provide all requested documents for verification. Failure to comply may result in delays or suspension of account services.
11. Handling Suspicious Transactions
- If suspicious or fraudulent transactions are detected, the Company may suspend account services, block the Client's account, and cancel any transactions pending investigation.
12. Documentation Requests During Investigations
- During investigations, the Company reserves the right to request identity documentation and proof of fund origin to confirm legality.
13. Prohibition on Illegal Activities
- The use of Company services or software for illegal or fraudulent activities, including money laundering, is strictly prohibited.
14. Company Liability
- The Company's refusal to process suspicious transactions does not create liability to the Client or third parties.
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