AML (Anti-Money Laundering) Policy and KYC (Know your client) Procedures

The anti-money laundering (AML) and counter terrorism funding policy of the Company is aimed at fulfilling the requirements of the rules and regulations that are internationally acceptable. The purpose is to ensure that our business is not used to facilitate money laundering and to comply with all applicable laws. The Company has zero-tolerance policy for money laundering activities.
The Company takes AML very seriously and any deviance from our practices will result in immediate action. The Company reserve the right to refund, deny or withhold any deposit made against this policy, or is suspected according to the applicable law, to be AML related (such as transfer to or from a suspected jurisdiction etc.).

AML LEGAL AND REGULATORY FRAMEWORK:

The AML regime is set out in the following legislation and regulations: The Proceeds of Crime Act 2002 (POCA), as amended by the:

Serious Organised Crime and Police Act 2005 (SOCPA); and the
Proceeds of Crime Act (Amendment) Regulations 2007;

The Terrorism Act 2000, as amended by the:

The Anti-Terrorism, Crime & Security Act 2001; and the
Proceeds of Crime Act (Amendment) Regulations 2007;
The Terrorism Act 2006;
The Money Laundering Regulations 2007; and
The Joint Money Laundering Steering Group (JMLSG) Guidance for the Financial Sector on the prevention of money laundering/combating terrorist financing.

KYC - identification and verification of new customers, deposits, transfers and withdrawals

In order to open up an account with The Company, the client must submit the following:
- Surname
- First Name,
- National I/D or Passport Number,
- Address,
- E-mail,
- Telephone
The client must also send a copy of his/hers National I/D. The National I/D should contain the following (all or some, according to the Company's discretion:
- A photo of the holder,
- The national I/D number,
- He holders full name,
- The holder's father's first name,
- The holder’s mother's first name,
- The holder’s nationality and place of birth,
- The holder's date of birth,
- The holder's place of birth,
- The holder's sex,
- The holder's address,
- The holder’s marital status,
- The holder's spouses details such as their National I/D number.
Further details and checks are performed upon a Customer depositing Funds. All accounts opened must be in the same name as the funder of the account. No third party funding will be accepted by The Company.
Verification against Credit Card slips or details supplied by The Company's Credit Card handlers and/or verification against bank transfers from clients after a transfer and/or verification against actual cheques will be cross checked against details already supplied by the customer. Only upon verification will the account be opened. Any discrepancy will not be tolerated and funds will be returned to sender in the same way that they were sent.
Credit Card deposits will be subject to our credit card clearing Company's fraud and anti-money laundering procedures.
All client withdrawals will be only be permitted to exactly the same account and exactly the same name from which original customer funds were received. There will be no third party transfers.
The funds will also be transferred in exactly the same way of the original funding of the account. For instance withdrawals requested by a customer that transferred his original deposit via Credit Card will receive his funds as a refund from his credit card, up to the maximum of his deposit.
Repeat credit card depositors or client depositing over $5,000 in total deposits will require further inspections.
Withdrawals will only take place after written and signed requests and copies identifying the bank account as the clients and corresponding to previously received documentation.
The Company will at its own discretion ask for further proof of identification should for any reason the Company employee's suspicions arise.
Suspicious activity such as the method of deposit, suspicious circumstances such number of transfers will be monitored.
Verification will be performed at the account opening or within a reasonable time after opening of the account. The methods will include document and non document methods.
In circumstances where The Company cannot form a reasonable belief on the customer's identity the account will not be opened. The Company customer account system does not allow for account opening unless verification has been done as per company policy.
Records will be maintained for 5 years of all identifying documents obtained from a customer – either a copy or a description of the document used to verify identification. Also any document which resolves any discrepancy discovered recording the identity will be kept.
Detecting and reporting suspicious activity.
Regarding high risk accounts appropriate extra due diligence procedures will be taken i.e. further documents, phone calls or meeting face to face with clients, bank references and certification of certain documents.
When deemed necessary we will perform additional monitoring of specific account activities.
We maintain systems and procedures to detect and require reporting of suspicious activity.