This AML Policy (hereinafter referred to as the “Policy”) sets forth the general rules and processes governing the implementation and conduction of procedures in accordance with the relevant Anti-Money Laundering Laws and Regulations. is committed to establishing and maintaining policies, controls, and procedures to manage and effectively mitigate the risks of money laundering and terrorist financing. is strongly committed to preventing the use of its operations for money laundering or any activity which facilitates money laundering, or the funding of terrorism or criminal activities.

This policy provides for program continuity despite changes in management or employee composition or structure.

The Board of Directors and Senior Management of are committed to a solid culture of compliance to ensure adherence to the company’s AML policies, procedures, and processes.


KYC CUSTOMER IDENTIFICATION PROGRAM’s Customer Identification Program procedures are in place to accurately identify the identifiable features of its customers. The CIP procedures provide full, reliable, and secure identity verification by checking data consistency. has adopted a sound CIP program that ensures reliable customer identification and verification procedure in the account opening and further monitoring procedures. The program procedures allow for a thorough verification of the true identity of the customer by using two layers of identification and verification.

The system does not under any circumstances permit any transaction to be made with incomplete identity verification information. obtains satisfactory evidenc of the identity and legal existence of persons applying to do business with it based on reliable documents or other sources and records that identity and other relevant information regarding the applicant in its files.

The first customer identity verification stage includes the following features:

  • First Name; Last Name; Email Address; Mobile Number
  • Verification of email and mobile are performed in the on-boarding process

A second layer of control verification is added to the CIP once the customer goes through the verification including: Passport; Drivers License; Proof of Address. Customer Identification Program is carried out before any financial transaction is made. Customer Verification Stages

  • Customer Identity is entered into’s platform.
  • Identity details are sent to our KYC software via API.
  • Identity details are verified using video identity verification process with real human verification specialist.
  • Identification and verification outcome/feedback is transmitted back to

The Verification Panel

The Verification Panel enables the user to check on real time the status of the customer’s verification details. It contains the following data:

  • Screenshots made during the verification stage.
  • Information about face verification (screen, results, status, reference screen)
  • ORC - document type, ghost portrait, data from OCR
  • Information about Customer (First name, Last name, ID number)
  • Notes State

Customer Verifications Case Details and History

  • Verifications case details and history contains the following data:
  • Verification join date
  • Verification join count
  • Verification queue position
  • Customer Verification Call-back URL
  • Mobile Verification Hash
  • State
  • Information about recording (checkbox)
  • Notes Verification Email opt in (checkbox)
  • Is iframe integration active (checkbox)
  • To confirm (checkbox)
  • Confirmed on
  • Confirmed by
  • Information about rate verification

Our KYC Software provides a full identification solution which is compliant with the highest level of KYC requirements. This process requires the presence of a trained verification for the whole duration of identity verification. It combines both the human element along with AI during identity process. Identification consists of an automated technology that simultaneously runs in the background to provide full, reliable and secure identity verification.

  • Checks and Data Consistency
  • Character recognition technology
  • Reads, analyses, and validates checksums on the document
  • Confirms that document has not expired
  • Makes verification for any signs of manipulation or forgery.


In determining the risk profile of a customer considers various parameters in categorizing its customers in assigned risk levels.

‘Customer Risk Categorization’ refers to the money laundering risk associated with a particular customer from’s perspective. This risk is based on the risk perceptions associated with the parameters comprising a customer’s profile. For an effective implementation of KYC, anti-money laundering (AML) and combating of financing of terrorism (CFT) measures, Risk Categorization of customers along with periodic updating of customer profile and monitoring in accounts is deemed especially important by

Know Your Transaction Program

KYT (Know Your Transaction) is a transaction monitoring solution designed to automate transaction monitoring and generate automated user risk profiles.

  • Individual user profile view provides key details about risk exposure and transactions.
  • The ability to filter and sort by risk score allows the Compliance Officer to identify the cases that require the most immediate attention.
  • In addition, real time screening captures the latest updated information into each unique user profile.
  • Moreover, the solution offers historical view for each data, action and record processed.
  • Case management functionality allows the Compliance Officer to review user profiles and keep track of decisions and annotations along with the historical data.

Politically Exposed Persons

A politically exposed person (PEP) is defined by the Financial Action Task Force (FATF) and as an individual who is or has been entrusted with a prominent public function. The regulatory requirements associated with PEPs justify the application of additional anti-money laundering / counter-terrorist financing (AML/CFT) effective customer due diligence and enhanced due diligence requirements to be conducted by with respect to business relationships with PEPs.

KYC Process relies on our KYC Software for PEP screening against global PEP lists before they can establish a relationship with its business. PEP List Screening Stages

  • Customer Identity is entered into’s platform.
  • Identity details are sent to our KYC software via API.
  • Identity details are screened against integrated PEP lists on the back of the identity verification check.
  • Identification and verification outcome/feedback for possible match is transmitted back to

CDD and Enhanced CDD Process

If possible, matching is identified from the API identity check and screening, undertakes the following:

  • Perform additional checks based on the intended nature of the business relationship.
  • Perform additional checks on the reasons for the intended transactions.
  • Perform additional checks on the source of funds.

On-going Monitoring Process

Ongoing monitoring of PEP’s is conducted periodically as part of the monitoring process or as a result of a triggering event.
A trigger event could include, but is not limited to:

  • A new application involving the same PEP
  • The receipt of a court order subpoena etc, against the client

The following information and documentation are reviewed – reconfirmed – updated when conducting a periodic review of a PEP client.

  • All KYC information
  • The relevance of the CDD conducted initially
  • Selecting patterns of transactions that need further examination
  • The relevance of the transaction’s amounts and transaction number rationale.

Non-Cooperative Countries and Territories does not open accounts or transact with individuals and/or entities that reside on Non-Cooperative Countries and Territories. abides to the FATF, OFAC Sanctions Lists and United Nations Security Council Sanction requirements for non conducting business with the prohibited Countries and Territories.

Specially Designated Nationals and Blocked Persons Lists does not open accounts or transact with individuals that reside on Non-Cooperative Countries and Territories. at the on-boarding process relies on our KYC Software for cross-checking of the Specially Designated Nationals and Blocked Persons Lists on the back of the identity verification check. Specially Designated Nationals and Blocked Persons List Screening Stages

  • Customer Identity is entered into’s platform.
  • Identity details are sent to our KYC Software via API.
  • Identity details are screened against integrated OFAC lists on the back of the identity verification check.
  • Identification and verification outcome/feedback for possible match is transmitted back to

COMPLIANCE OFFICER has designated a qualified individual to serve as Compliance Officer, responsible for coordinating and monitoring day-to-day AML compliance. The Compliance Officer is also charged with managing all aspects of the AML compliance program and with managing the company’s adherence to the regulatory requirements and its implementing regulations.

The Compliance Officer has a direct reporting line to the Senior Management and the specific job profile is solely focused on the AML / CTF framework guaranteeing no conflict of interest with other duties that fall outside the scope of this framework. undertakes a “Know Your Employee” program consisting of a Pre-Employment Background Screening for the Compliance Officer and other staff linked to similar duties, which includes but is not limited to the verification of references, experience, education, professional qualifications and has no criminal record.

Duties and Responsibilities of the Compliance Officer

  • Serving as a point of contact for providing information requests by government agencies and regulatory bodies.
  • Collecting, evaluating, and monitoring Clients’ identification information.
  • Establishing, maintaining, and updating internal policies, procedures and controls.
  • Establish clear record keeping procedures for all necessary records on customers and transactions, both domestic and international.
  • Monitoring transactions and investigating any significant deviations from normal activity.
  • Updating risk assessment regularly.
  • Providing AML and CTF training.
  • Coordinating AML compliance program.
  • Monitoring KYC and CDD related screening.

RECORD-KEEPING documents all the required identifying information provided by a Client, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. keeps records of any document relied on to verify a Client’s identity. With respect to non-documentary verification, retains documents that describe the methods and the results of any measures taken to verify the identity of a Client. In addition, records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained are kept accordingly.

The following minimum retention periods are implemented:

  • Account opening records – copies of identification documents are to be kept in file for 5 years following the closing of an account.
  • Account ledger records – 5 years from entering the transaction into the ledger;
  • Records in support of entries in the accounts (e.g. credit/debit slips and cheques and other forms of vouchers) – 5 years from when the records were created; and
  • Records in support of exchange transactions - 5 years from when the transaction occurred.

The Compliance Officer performs periodic checks to assess the completeness of physical documentation against electronic records.

The documents are retained in acceptable forms which are in line with the regulatory requirements and industry standards.

In situations where the records relate to ongoing investigations, or transactions which have been the subject of a disclosure, they are retained until it is confirmed that the case has been closed.

SUSPICIOUS ACTIVITY MONITORING AND REPORTING has systems in place to enable the recognition and reporting of unusual or suspicious transactions:
“Suspicious Transaction” means a transaction or attempted transaction, which to a person acting in good faith:

  • Gives rise to a reasonable ground of suspicion that it may involve proceeds of criminal or other illicit activity, regardless of the value involved.
  • Appears to be made in circumstances of unusual or unjustified complexity;
  • Appears to have no economic rationale or bona fide purpose; and
  • Gives rise to a reasonable ground of suspicion that it may involve financing of the activities relating to terrorism.

Ongoing monitoring is an essential element of the effective AML framework implementation. diligently monitors customers and transactions for any suspicious activity. Transactions that are unusual are carefully reviewed and further analysed to determine if it appears that they make no apparent sense or appear to be suspicious.

The following indicators will act as Money Laundering Warning Signs based on guidance provided by Financial Action Task Force (FATF) – international body set up to combat money laundering:

  • Evasiveness or reluctance to provide information.
  • Incomplete or inconsistent information.
  • Unusual money transfer or transactions.
  • Complex group structures without obvious explanation that may be designed to disguise the true source and ownership of money.
  • When money is coming from the list of ‘high-risk and non-co-operative jurisdictions’ according to FATF.
  • Negative public information available about the client or company.

When such suspicious activity is detected, the Compliance Officer will determine whether a filing with any law enforcement authority is necessary based on further analysis. The Compliance Officer initially makes the decision of whether a transaction is potentially suspicious. Once the Compliance Officer has finished his review of the transaction details, makes the decision as to whether the transaction meets the definition of suspicious transaction or activity and whether any filings with law enforcement authorities should be made. has created a register, which is maintained by the Compliance Officer and is used to keep track of all the reports made to the regulatory bodies and other governmental law enforcement agency. uses standard format for each AML / CTF related reporting. retains evidence for reporting relevant information obtained from an applicant with who has not established business relationship because of concerns about potential criminal activity.

If a suspected case has been reported as SAR, and it becomes necessary to make further enquiries of the customer, exercises great care to ensure that the customer does not become aware that his/her name has been brought to the attention of the law enforcement agencies.

TIPPING OFF abides to the Anti Money Laundering applicable laws that make an offence to disclose information that is likely to prejudice an investigation if the person knows that an investigation into money laundering is being, or is about to be, conducted, or if he knows that a disclosure has been made and that reporting such information is likely to prejudice the subsequent investigation. considers “Tipping off” not just an offence committed by communicating with suspected clients, but also other parties connected to the suspected client including advisers or family members.

All members of staff are fully aware of their personal obligations under the tipping off legal obligations.

The Compliance Officer and other relevant staff are obligated to keep all communications relating to a suspected client with the utmost care.


All new employees receive anti-money laundering training as part of the mandatory new-hire training program. All existing employees are also required to complete AML and KYC training periodically. Participation in additional targeted training programs is required for all employees with day-to-day AML and KYC responsibilities.

The training is delivered periodically to the relevant staff, is designed to be adapted to the specific line of business and needs and is always updated based on the latest statutory and regulatory requirements. Training needs are regularly reviewed to check whether certain employees require specialized additional training. Trainings are documented accordingly.

The training includes:

  • Current developments and changes to the related regulations.
  • AML / CTF internal controls, monitoring systems, policies and procedures.
  • Employees' roles in understanding their specific role in maintaining an effective AML framework.
  • KYC and CDD procedures.
  • Personal legal staff obligations under the relevant AML regulatory requests and the expected responsibilities relating to AML.
  •’s record retention requirements.


Independent testing (audit) is conducted periodically. The AML / CTF compliance framework testing is reported directly to the Board of Directors. The auditing process is based on a periodic and independent evaluation of the AML policies and procedures, and verifies such compliance.   
The audit is risk based and designed for conducting an objective independent evaluation of the:

  • AML compliance program adequacy of the policies and procedures
  • The integrity of DATA and Reports generated by the MIS.
  • The adequacy of internal controls
  • The adequacy of record keeping requirements
  • The adequacy, accuracy, and completeness of the AML training material
  • The effectiveness of the suspicious activity monitoring system
  • CIP is adequately incorporated.

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