Anti-Money Laundering Policy
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Money Laundering is the process of converting funds received from illegal activities (such as fraud, corruption, terrorism, etc.) into other funds or investments that appear to be legitimate in order to hide or distort the real source of funds.
The money laundering process can be divided into 3 consecutive stages:
Placement. At this stage, the funds are converted into financial instruments such as checks, bank accounts, and money transfers or can be used for purchasing high-value goods that can be resold. They can also be physically deposited in banks and non-bank institutions(e.g., currency exchangers). To avoid suspicion on the part of the company, the launderer may as well make several deposits instead of depositing the whole sum at once; this form of placement is called smurfing.
Layering. Funds are transferred or moved to other accounts and other financial instruments. It is performed to disguise the origin and disrupt the indication of the entity that made the multiple financial transactions. Moving funds around and changing their form makes it difficult to track money being laundered.
Integration. The funds are returned to circulation as legitimate for the purchase of goods and services.
Loyal Primus Ltd, like the majority of companies providing services on the financial market, adheres to Anti-Money Laundering principles and actively prevents any actions aimed at or facilitating the process of legalization of illegally gained funds. AML policy means preventing the use of the Company’s services by criminals for the purpose of money laundering, terrorist financing, or other criminal activities.
For this purpose, the Company introduced a strict policy on detecting, preventing, and warning the corresponding bodies of any suspicious activities.
Moreover, the Company has no right to report Clients that the law enforcement bodies are informed of their activity. A complex electronic system for identifying every Company’s Client and conducting a detailed history of all operations has also been introduced.
To prevent money laundering, the Company neither accepts nor pays cash under any circumstances. The Company reserves the right to suspend any Client’s operation that can be regarded as illegal or may be related to money laundering in the opinion of the staff.
The Policy must be communicated to all Company employees that manage, monitor, or control in any way customers’ transactions and are responsible for applying the practices, measures, procedures, and controls that have been determined herein. This Policy also applies to all company officers, designated contractors, agents, products, and services the Company offers. All business units within the Company will cooperate to create a cohesive effort to fight against money laundering.
This Policy’s appropriateness, effectiveness, and adequacy are the subject of an independent Internal Audit.
The Company will ensure that it is dealing with a real person or legal entity. The Company also performs all required measures following applicable laws and regulations issued by the monetary authorities. AML policy is being fulfilled within the Company through the following:
Know Your Customer Policy and Due Diligence;
Monitoring of Client Activity;
The Company assesses and evaluates the risks it faces based on the customer’s nature, customer’s behavior, customer’s initial communication with the Company, as well as the risks based on the Company’s services and securities.
Due to the Company’s commitment to the AML and KYC policies, each Company’s Client must complete the verification process. Before the Company commences any cooperation with the Client, the Company shall ensure that satisfactory evidence is produced or other measures are taken that will produce satisfactory evidence of the identity of any customer or counterparty. The Company also applies enchased scrutiny to Clients who are residents of the countries identified by credible sources as countries having inadequate AML standards or may pose a high risk of crime and corruption and to beneficial owners who reside in and whose funds are sourced from named countries.
Each Client provides personal information during the registration process, specifically: full name, date, place of birth, residential address, business address, phone number, and city code.
Individual Client sends the following documents (if 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 into English) due to KYC requirements and to confirm the indicated information:
Identity should be verified by:
Valid Passport; or
National ID Card; or
Current driver’s license with a photo; or
Any other government-issued identification document.
The indicated documents must contain: the full name, date of birth, photo, and citizenship of a customer, and also, where applicable: confirmation of the document validity (issue and/or expiry date), and holder’s signature.
The indicated documents must be valid for at least 6 months from the filing date.
For the purposes of the provisions relating to identification procedures and CDD
requirements, proof of identity is satisfactory if:
it is reasonably possible to establish that the customer is the person he claims to be; and,
the person examining the evidence is convinced, in accordance with the procedures followed under the relevant legislation and regulations, that the customer is actually the person he claims to be.
The current residential address will be verified by one of the followings:
A recent utility bill; or
Bank statement; or
Credit card statement (monthly); or
Tax identification numbers, Social Security number or Government Service and Insurance System number.
The utility bill, bank statement, and credit card statement should not be older than 3 months from the filing date. Whereas a copy of the customer’s tax identification number, Social Security number, or Government Service and Insurance System number should be apostilled in the country of origin upon the Company’s request.
Where the certification is required, the documents must be certified by either one of the
a notary public;
an attorney-at-law; or
a Commissioner of Oaths.
Both sides of the submitted document are required where applicable (for example, ID or Driver’s License). The document image must be a color, high-resolution photo, or scanned copy with no blurs, light reflections, or shadows. The four edges of the document should be visible. All information must be clearly readable, free of any watermarks, etc.
For each account, the Company shall also make a reasonable effort, before the settlement of the initial transaction, to obtain the following information to the extent it applies to the account:
Occupation of customer;
The customer’s investment objective and other related information concerning the customer’s financial situation and needs;
Annual income, Assets or net worth.
In case the applicant company is listed on a recognized or approved stock exchange or where there is independent evidence showing that the applicant is a wholly-owned subsidiary or subsidiary under the control of such a company, no further steps to verify identity will normally be required.
In case the Company is unquoted, and none of the principal directors or shareholders
already has an account with the Company, the official provides the following documents
because of the requirements of KYC:
Copies of the Certificate of Registration/Certificate of Incorporation;
Copies of the Memorandum and Articles of Association, Partnership Agreement, or similar, as appropriate;
Copies of the By-Laws and latest General Information Sheet, which lists the names of directors/partners and principal stockholders, and secondary licenses;
Extract from Commercial Register, or equivalent document, proving the registration of
corporate acts and amendments and current state of the legal person such as Certificate of
Copy of the Certificate of Incumbency issued not older than 3 months from the filing date;
Information about the BOs of the company from the independent and reliable sources;
KYC documents of all Directors, Shareholders, BO’d, and Officers of the legal person
Appropriate Board of Directors’ resolutions and signed application forms or account opening, identifying the authorized signatories or principal officers of the corporation authorized to open an account, to trade and their authorities and specimen signatures;
Evidence of the registered address and actual place of business of the legal person;
Latest Audited Financial Statements;
Where applicable, the Company may also require additional information about the nature of customers’ business, such as the description and nature of business (including date of commencement of business, products or services provided, and principal place of business).
This procedure is performed to establish the Client’s identity and help the Company know/understand Clients and their financial dealings to be able to provide the best services of online trading.
If, during the business relationship, a customer fails or refuses to submit, within a reasonable timeframe, the required verification data and information, the Company shall terminate the business relationship and close all the accounts of the customer.
Customer due Diligence regarding the Individual Clients and Corporate Clients shall be updated and/or amended soon after any changes occur. This applies to a change of residence or business address, new identification cards, a new passport, additional business information, new business securities/ventures, and the like. For any information change before the said period, the Company requests a letter or document pertaining to the changes being made.
In addition to gathering information from Clients, the Company continues to monitor the activity of every Client to identify and prevent any suspicious transactions. A suspicious transaction is known as a transaction that is inconsistent with the Client’s legitimate business or usual Client’s transaction history known from the Client activity monitoring. The Company has implemented a system of monitoring the named transactions (both automatic and, if needed, manual) to prevent using the Company’s services by criminals.
The Сompany reserves the right to suspend any Сlient’s operation which, in the staff’s opinion, can be regarded as illegal or may be related to money laundering.
The constant monitoring of the customers’ accounts and transactions is an imperative element in effectively controlling the risk of Money laundering.
All Clients’ operations on depositing and withdrawing funds have the following requirements:
in the case of bank transfer or transfer from the bank card, the name indicated during the registration must match the name of the owner of the account/bank card. It is possible to withdraw funds from the account via bank transfer only in the same bank and the same account you used for depositing;
in the case of using electronic payment systems, withdrawing funds from the trading account is possible only on the system and the account used for depositing;
if the account has been credited in a way that cannot be used for funds withdrawal, the funds might be withdrawn to a bank account of the client or any other way may be used, as agreed with the Company, through which the Company can prove the identity of the account holder;
if the account has been credited with funds through various payment systems, funds withdrawal shall be made on a pro-rata basis commensurate to the size of each deposit. Any profit gained can be transferred to any account from which the deposit was received if the transfer is possible;
no deposits and withdrawals to the bank accounts, bank cards, electronic money, or any other kind of payment accounts of third parties are allowed.
Records will be kept for all documents obtained for the purpose of customer identification (KYC policy requirements) and all data of each transaction, as well as other information related to ML, under the applicable AML laws/regulations.
The following document retention periods will be followed:
All documents in opening the accounts of customers and records of all their transactions, especially customer identification records, shall be maintained and safely stored for seven (7) years from the dates of transactions;
With respect to closed accounts, the records on customer identification, account files, and business correspondence shall be preserved and safely stored for at least seven (7) years from the dates when they were closed.
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