ANTI MONEY LAUNDERING POLICY AND PROCEDURES 

Signed by AML Officer: Sophia Alice Barlow

Signed by Director: Graham Peter Bowles

The risk of company services being used by would be launderers or for terrorist financing involves significant reputational, legal and regulatory risks. Senior management has a responsibility to ensure that the firm’s controls and procedures are appropriately designed and implemented to minimise the risk of the firm exposure to potential ML or TF. The founders and board of directors of Company have reviewed and approved this policy in relation to ML/TF prevention at their meeting on 21st of March 2022. Founders and board of directors of Company, recognize that commitment to the highest standards in relation to issues of Client Due Diligence (CDD), Money Laundering (ML) and Terrorism Finance (TF) Procedures is fundamental to the successful operation of the business.

AML Officer is in charge of implementing this policy and specific procedures in order to allow proper identification of clients, prevention of money laundering and terrorism financing and adequate training of company personnel in CDD/ML/TF procedures. All company employees are obliged to remain vigilant and aware at all time of ML/TF issues.
 
All participants of Moneysend transactions shall provide AML Officer with the necessary documents, such as proof of identity and proof of address, as well as any other documents if necessary.

Identity Proof (Passport, Driving License)
Address Proof (Passport, Electricity Bill, Bank Account Statement, Gas Bill, Lease agreement along with last 3 months, rent receipt)
 
Customers Who Provide Insufficient or Suspicious Information
 
-A customer uses unusual or suspicious identification documents that cannot be readily verified

-A customer’s home or business telephone is disconnected

-The customer’s background differs from that which would be expected on the basis of his or her business activities

In addition to the information and documentation provided by or on behalf of the Customer or obtained from the Third parties (where relevant), the AML Officer has to check the below sources to verify the provided information is correct or to establish the missing information for the Customer:

(1) use of World Check services;

(2) internet search engines (e.g. www.politsei.ee, www.google.com and other, especially in cases of PEPs);

(3) checks in the consolidated lists of persons, groups and entities subject to EU or United Nations financial sanctions; http://eeas.europa.eu/cfsp/sanctions/consol-list/index_en.htm; https://www.un.org/sc/suborg/en/sanctions/un-sc-consolidated-list;

(4) public registers https://www.gov.uk/government/publications/overseas-registries and other).

  does not work with residents of sanctioned countries (AFG, CAF, COD, CUB, IRN, IRQ, LBN, LBY, MLI, MMR, PAK, PRK, PSE, SDN, SOM, SSD, SYR, VEN, YEM, ZWE, TTO, BHS, MNG, GHA)