Anti-Money Laundering and Countering Financing of Terrorism Policy

Objectives of the Policy

• Meet applicable legal requirements and international standards in jurisdictions where the Company operates;
• Detect, prevent and combat abuse of the Company’s services for the purpose of money laundering and terrorism financing;
• Mitigate reputational and financial risks to Company;
• Avoid being involved in any kind of illegal activities and violation of applicable legislation.

Key Provisions

The Company has adopted and implemented a continuous risk-based approach to identify, assess and understand its ML and TF risks. It also ensures measures to mitigate ML and/or TF are commensurate with the risks identified, enabling decisions on how to allocate its resources in the most effective way.

Under this approach we adhere to the following procedures to manage AML/CFT risk:

a) Executing Know Your Customer (“KYC”) procedures. As a part of internal control we verify and identify our customers, which use our services provided through the Website. For this purpose, we attempt to collect, verify, and authenticate the following information:

• Full legal name;
• Date of birth;
• Proof of identity;
• Home address (not a mailing address or P.O. Box); and
• Additional information or documentation at the discretion of our Compliance Team

In case the customer doesn't have an opportunity to provide the documents in Latin or Cyrillic alphabet above-mentioned alphabets the Company reserves the right to demand video verification where the customer shows his/her documents.

b. Due Diligence (DD). We conduct manual check of customer’s withdrawals. Any suspicious withdrawal leads to enhanced DD and freezing of the customer’s account. Enhanced DD includes i) obtaining additional information on the customer (e.g. occupation, volume and assets, information available through public databases, internet etc.); ii) obtaining information on the source of funds or source of wealth of the customer; iii) obtaining the approval of senior management to commence or continue the business relationship.

c. Monitoring. We conduct ongoing and regular monitoring of potentially risk placement of funds by customers. In case of suspicious placement of funds customer’s account and funds are freezed and enhanced due diligence is conducted.

d. Cooperation with Customers. We do not engage with, and will terminate the existing relationship if any, with customers who i) do not cooperate with DD and KYC efforts; ii) is engaged in money laundering and financing of terrorism.

In case the Customer fails to provide complete or provides false information required under KYC or DD procedure the withdrawal is refused and the Customer’s Account terminated.

e. Designating MLRO and Reporting. A Money Laundering Reporting Officer (MLRO) is designated by the Company to ensure implementation and oversight the Policy. Any suspicious information on customer’s transactions and activity on the Website or any other red flag that comes to the knowledge of Company’s employees is immediately reported MLRO Officer as a part of internal control without informing the Customer that a suspicious activity is being reported or investigated.

f. Risk Profiles. We develop risk profiles to determine the customer categories which expose the Company to higher risk. High risk customers include: customers from countries identified as not having adequate AML/CFT systems, customers from countries subject to sanctions, embargos or similar measures imposed by the UN, customers from countries identified as having significant levels of corruption or other criminal activity, customers from countries or geographic areas identified as providing funding or support for terrorist activities, or that have designated terrorist organizations operating within their country.

g. Internal Control. We develop internal policies, procedures, and controls designed to comply with applicable AML and CFT laws and regulations, which include but not limited to, KYC procedure, developing risk profiles, filing of suspicious activity reports and suspicious transactions reports, and other reporting requirements and audits.

h. Keeping Records. We keep for at least 5 (five) years all records obtained through DD measures and documentation regarding our relations with customers and customers’ transactions, as well as correspondence with the customers.

i. Training Program. All of our employees and officers regularly receive ongoing broad-based AML/CFT training, as well as position-specific training.

Training sessions in order to identify ML and TF for Customer support team and Payment officers team are organized on monthly basis via Antifraud team. Antifraud team gets monthly training sessions from MLRO in order to increase understanding of ML and TF cases.

All documentation related to compliance training including materials, tests, results, attendance and date are maintained. In addition, our compliance training program is updated as necessary to reflect current laws and regulations.

The present Policy shall be regularly reviewed and, if necessary, revised in an effort to comply with applicable rules, regulations, policies, and best practices.