1. OBJECTIVE OF THE AML POLICY
Our company is abiding by the anti-money laundering (AML) requirements applicable to our type of
business. To manage and reduce the risk of our company being used by criminal elements, all our staff
is focusing on pursuing the highest standards of AML and Know Your Customer (KYC) regulations.
To make sure that all the necessary steps are taken to achieve the full safety of our services, we have implemented the framework of AML Policy. In this AML Policy we are committed to follow the
provisions specified in the Estonian AML laws, EU and international AML guidelines.
2. WHAT IS AML POLICY?
AML Policy is the set of rules we put in place to make sure our services are not being used for money
laundering, terrorist financing or any other type of criminal activity. KYC measures are part of the
AML Policy. These are meant to empower businesses, by helping them to know and understand their
customers better and manage the specific risks. KYC procedures are susceptible to be updated in the
future, to make sure compliance with the existing laws and best AML practice is perfected.
If any potentially suspicious or unusual transactions or customer’s behavior arise, we undertake the
appropriate measures to address the risks. Additional documents, such as proof of funds’ sources etc,
might be asked from the customers, by staff handling transactions. When it comes to keeping records,
we have put in place a well-organized procedure, to ensure all identification documents and data related
to transactions is stored confidentially and according to personal data protection laws.
Our AML Policy comprises:
- Customer identification and verification before starting a commercial business relationship.
- Establishing and maintaining the risk-based customer due diligence including enhanced due diligence
for high risk customers.
- Transactions monitoring of the client’s financial behavior, following risk-based analysis.
- Regulations about how to report suspicious activity internally and to the required law enforcement
- Periodical AML staff trainings.
We are forced to reject the customer’s documents, close their account and terminate the business
relationship in case any suspicious activity is found, if the customer provides false documents or fails
to cooperate with the company during the customer due diligence process.