The Anti-Money Laundering, Countering the Financing of Terrorism and Know Your Customer Policy (hereinafter referred to as the “AML/CFT Policy”) of Transfer24.pro is designed to prevent and reduce the potential risks of Transfer24.pro participating in any illegal activity.
Money laundering is defined as
- The transformation or transfer of property derived from criminal activity or property obtained in lieu of such property, knowing that such property is derived from criminal activity or participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person engaged in the commission of such activity to evade the legal consequences of that person’s actions;
- the acquisition, possession or use of property derived from criminal activity or property obtained in lieu of such property, knowing at the time of receipt that such property is derived from criminal activity or participation in such activity;
- the concealment or disguise of the true nature, source, location, disposition, movement, rights in or ownership of property derived from criminal activity or property obtained in lieu of such property, knowing that such property is derived from criminal activity or participation in such activity activities.
Money laundering also means participating in, complicity in, attempting to commit, and aiding, abetting, facilitating and counseling the commission of any of the acts mentioned above.
Terrorist financing is defined as the financing and support of a terrorist act and the commission of such an act, as well as the financing and support of travel for the purpose of terrorism.
Both international and local laws and regulations require Transfer24.pro to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery, and to take action in the event of any form of suspicious activity of its Users.
The AML/CFT policy covers the following issues
- Internal controls
- Compliance officer;
- Staff training;
- Verification procedures;
- Monitoring, risk assessment and risk-based approach;
- Auditing the AML/CFT program.
Internal controls
We have developed a structured systеm of internal controls to comply with applicable anti-money laundering and counter-terrorist financing (“AML/CFT”) laws and regulations, including, but not limited to:
- Customer identification and verification of information provided;
- Establishing a special regime for working with customers who are politically exposed persons (PEPs);
- Identifying unusual activities and facilitating the reporting of suspicious activity (SAR);
- keeping records of customer documentation and transaction history.
Security Service
The Security Officer is a person duly authorized by Transfer24.pro whose duties inсlude developing and ensuring the effective implementation of AML/CFT. The Security Officer is required to report any breaches of AML/CFT procedures and is responsible for collecting and filing SARs.
The Security Officer is required to oversee all aspects of Transfer24.pro’s anti-money laundering and counter-terrorist financing measures, including but not limited to:
- establishing and updating internal policies and procedures for the completion, verification, submission and retention of all reports and records required by applicable laws and regulations;
- collecting identification information from Users and verifying the information provided; implementing a records management systеm for the proper storage and retrieval of documents, files, forms and logs;
- collecting and analysing information regarding unusual transactions or transactions or circumstances suspected of money laundering or terrorist financing that have become apparent;
- investigating any unusual, suspicious activity;
- reporting to the appropriate authorities in the event of a suspicion of money laundering or terrorist financing; providing information to law enforcement agencies in accordance with the requirements of applicable laws and regulations;
- periodically submitting written statements to the management on compliance with the requirements arising from the law;
- organising employee training;
- performing other duties and responsibilities related to compliance with the requirements of the law;
- regularly updating the risk assessment.
The security officer has the right to interact with law enforcement agencies that are engaged in the prevention of money laundering, terrorist financing and other illegal activities.
Verification procedures
Transfer24.pro establishes its own procedures for checking clients within the framework of AML/CFT standards, and also conducts a comprehensive check and KYC check before entering into a business relationship with a customer, client, contractor.
During the process of due diligence and KYC, as well as for opening an account, the identity of the person, the information provided about the person and the documents submitted must be checked and verified against the sanctions lists and watch lists, including the list of politically exposed persons. For this, Transfer24.pro uses special tools, a structured verification and verification systеm.
In relation to legal entities (their owners/shareholders/beneficiaries, etc.), Transfer24.pro conducts special enhanced due diligence, KYC, compliance procedures.
Transfer24.pro provides a dedicated advanced identification, KYC, due diligence and compliance procedure for clients designated as politically exposed persons, regardless of their place of residence.
Monitoring, risk assessment and risk-based approach
Transfer24.pro monitors clients’ transactions, assesses risks and detects suspicious activity. For this purpose, a specially developed systеm is used, including the use of high-performance tools.
Transfer24.pro uses a risk-based approach to combating/preventing money laundering and/or terrorist financing.
To help determine the level of AML/CFT due diligence in relation to a client, the compliance risk profile is calculated first at the onset of the relationship (Low, Medium, High), and then recalculated on a planned basis.
AML/CFT compliance ensures ongoing transaction monitoring to identify transactions that are unusual or suspicious compared to the client’s profile.
Determining the unusual nature of one or more transactions depends heavily on subjective assessment regarding the client’s knowledge (KYC), financial behavior, and the counterparty to the transaction.
If a transaction is inconsistent with the client’s known personal routine or personal habits, the transaction may be considered suspicious. Data and transaction monitoring tools are used to identify unusual/unusual patterns of client behavior. After review and investigation, the compliance officer will decide whether or not to file a SAR.
Once a SAR is filed with the relevant agency, a copy of the filing documentation is retained. The SAR filing is confidential and only Transfer24.pro employees involved in the investigation and reporting process will be aware of its existence.
All records are retained for a minimum of (5) years and are available upon formal request from an authorized examiner, regulator, or law enforcement agency.
Any Transfer24.pro employee must inform the Compliance Officer of any unusual transactions they observe that cannot be attributed to legitimate activity or the known source of the client’s income.
AML Audit
The Security Service is responsible for conducting an AML/CFT audit at least once a year. Other audit requirements are set out in internal policies and procedures.
We apply due diligence measures, in particular
- when establishing a business relationship;
- when verifying information obtained during due diligence measures or in case of doubts about the sufficiency or reliability of previously collected documents or data when updating relevant data;
- when there is a suspicion of money laundering or terrorist financing;
- in certain other cases, including in other specific cases provided for by law and in cases of detection of “red flags” in accordance with internal procedures.
Retention of data
We retain originals or copies of documents serving as the basis for identification and verification of persons, as well as documents serving as the basis for the establishment of a business relationship for at least five years after the termination of the business relationship.
We retain documents prepared in relation to a transaction on any storage medium, as well as documents and data that give rise to notification obligations, for at least five years after the transaction has taken place or the reporting obligation has been met.
Our monitoring of business relationships includes
- reviewing transactions made within the framework of the business relationship to ensure that the transactions are consistent with our knowledge of the client, its activities and risk profile;
- regularly updating relevant documents, data or information collected in the course of the application due diligence measures;
- determining the source and origin of funds used in a transaction;
- paying greater attention to transactions that may be associated with money laundering or terrorist financing, including complex, high-value and unusual transactions and patterns of transactions that have no reasonable or apparent economic or legitimate purpose or are not typical for the specific business;
- paying greater attention to business relationships or transactions in which the customer (or the customer’s payment service provider, etc.) is located in a high-risk third country or a country or territory defined by law as a country or jurisdiction with factor(s) that increase the risk of geographic risk.
