1. 1.1. As a company, we are committed to carrying on business in accordance with the highest ethical standards. This includes complying with all applicable laws and regulations aimed at combating money laundering and terrorist financing. This Policy has been developed by our Company to reduce the risk of money laundering and terrorist financing associated with its business and the sale of its services and/or products. This Policy explains our individual responsibility in complying with anti-money laundering and counterterrorist financing laws ("AML Laws") around the world and ensuring that any third parties that we engage to act on our behalf, do the same.
  2. 1.2. The management of the Company is committed to complying with all laws. Any employee who violates the rules in this Policy or who permits anyone to violate those rules may be subject to appropriate disciplinary action, up to and including dismissal, and may be subject to personal civil or criminal fines.
  3. 1.3. If you have any questions about this Policy you should contact the Compliance or the Legal Department.

2. Policy Statement on AML

  1. 2.1. It is our Company's policy to comply with all applicable AML Laws in our operations worldwide. To this end, our Company will only conduct business with customers who are involved in legitimate business activity and whose funds are derived from legitimate sources.
  2. 2.2. This Policy is intended to help employees, contractors, and other third parties acting on the Company's behalf to understand where breaches of AML Laws might arise and to support them in making the right decisions in line with our corporate position as stated in this Policy.

3. Who is subject to this Policy?

  1. 3.1. This Policy applies to the Company's operations globally and to all directors, officers, employees, contractors, and other third parties acting on behalf of the foregoing.

4. What is the risk?

  1. 4.1. Violations of AML Laws may lead to severe civil and/or criminal penalties against companies and individuals, including significant monetary fines, imprisonment, extradition, blacklisting, revocation of licenses, and disqualification of directors.
  2. 4.2. In addition, violations of AML Laws can lead to damaging practical consequences, including harm to reputation and commercial relationships, restrictions in the way we can do business, and extensive time and cost in conducting internal investigations and/or defending against government investigations and enforcement actions.

5. What do we mean by Money Laundering and Terrorist Financing?

  1. 5.1. Money laundering means exchanging money or assets that were obtained criminally for money or other assets that are ‘clean'. The clean money or assets don't have an obvious link with any criminal activity. Money laundering also includes money that's used to fund terrorism, however it's obtained.
  2. 5.2. The following types of activities are considered to be “money laundering” and are prohibited under this Policy:

    • a) the conversion or transfer of property (including money), knowing or suspecting that such property is derived from criminal or certain specified unlawful activity ("criminal property"), for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such activity to evade the legal consequences of his action;
    • b) conducting a financial transaction which involves criminal property;
    • c) the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, ownership or control of criminal property;
    • d) the acquisition, possession or use of criminal property;
    • e) promoting the carrying on of unlawful activity; and
    • f) participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions mentioned in the foregoing points.
  3. 5.3. The definition of money laundering means that anybody (including any Company’s employee) could be in violation of the law if he/she becomes aware of, or suspects, the existence of criminal property within the business and becomes involved in or continues to be involved in a matter which relates to that property being linked to the business without reporting his/her concerns.
  4. 5.4. Property can be criminal property where it derives from any criminal conduct, whether the underlying criminal conduct has taken place in the country where you are situated or overseas.
  5. 5.5. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

6. Red Flags

  1. 6.1. Where any suspicions arise that criminal conduct may have taken place involving a customer, colleague or third party, you should consider whether there is a risk that money laundering or terrorist financing has occurred or may occur.
  2. 6.2. Some examples of red flags to be reported include:

    • A customer provides insufficient, false or suspicious information or is reluctant to provide complete information;
    • Methods or volumes of payment that are not consistent with the payment policy or that are not customarily used in the course of business, e.g., payments with money orders, traveller's checks, and/or multiple instruments, and payments from unrelated third parties;
    • Receipts of multiple negotiable instruments to pay a single invoice;
    • Requests by a customer or partner to pay in cash;
    • Payment to or from countries considered high risk for money laundering or terrorist financing;
    • Orders or purchases that are inconsistent with the customer's trade or business;
    • Payments to or from third parties that have no apparent or logical connection with the customer or transaction;
    • Payments to or from countries considered to be tax havens or offshore jurisdictions;
    • Payments from countries unrelated to the transaction or not logical for the customer;
    • A customer's business formation documents are from a tax haven, or a country that poses a high risk for money laundering, terrorism or terrorist financing, or a country that is not logical for the customer;
    • Overpayments followed by directions to refund a payment, especially if requested to send the payment to a third party;
    • Any customer for whom you cannot determine the true beneficial owner;
    • Structuring transactions to avoid government reporting or record keeping requirements;
    • Unusually complex business structures, payment patterns that reflect no real business purpose;
    • Wire transfer activity that is not consistent with the business activities of the customer, or which originates or terminates with parties unrelated to the transaction;
    • Unexpected spikes in a customer's activities.

The above is not intended to be an exhaustive list. Deviation from customer and accepted business practice should alert you to further investigate the activity in accordance with this Policy.

7. Compliance controls

  1. 7.1. Senior management of the Company are responsible for ensuring that the business has a culture of compliance and effective controls to comply with AML laws and regulations to prevent, detect and respond to money laundering and counter-terrorism financing and to communicate the serious consequences of non-compliance to employees.
  2. 7.2. For compliance purposes, the Company implemented the following:

    • Adoption of a risk-based approach;
    • Know Your Client (KYC) Policy and Customer Due Diligence;
    • Customer activity monitoring;
    • Record Keeping.

    Identification of the money laundering risks of customers and transactions allows the Company to determine and implement proportionate measures to control and mitigate these risks.

  3. 7.3. Country Risk

    In conjunction with other risk factors, the Company provides useful information as to potential money laundering risks. Factors that may result in a determination that a country poses a heightened risk include:

    • Countries subject to sanctions, embargoes, or similar measures;
    • Countries identified by the Financial Action Task Force (“FATF”) as non-cooperative in the fight against money laundering or identified by credible sources as lacking appropriate money laundering laws and regulations;
    • Countries identified by credible sources as providing funding or support for terrorist activities.
  4. 7.4. Customer Risk

    There is no universal consensus as to which customers pose a high risk, but the below-listed characteristics of customers have been identified with potentially heightened money laundering risks:

    • Armament manufacturers;
    • Cash intensive business;
    • Unregulated charities and other unregulated “non-profit” organisations.
  5. 7.5. Customer Acceptance

    It is our policy to carry out due diligence ("DD") at the outset of any business relationship and, if necessary, where any red flags arise subsequently on our customers, suppliers, distributors, counterparties, agents and any person with whom the Company has an established business relationship that will involve the transfer to or receipt of funds ("Customers"), so we can be satisfied that they are who they say they are and so that we can ensure that there are no legal barriers to working with them before contracts are signed or transactions occur. Various factors will determine the appropriate forms and levels of screening.

    The Company obtains sufficient information in order to undertake its risk assessment and determine the potential exposure to ML/FT risks and to justify the applicable level of due diligence to mitigate those risks.

    The Company obtains sufficient detail from merchant applications to enable it to assess the risks. Relevant information contained therein might be corroborated by either appropriate electronic means or by suitable documentation. Initial due diligence should be supported by the use of transaction monitoring to assist in the identification of activity (such as volume of transactions, etc.) that may be indicative of money laundering and other illegal activity.

    Therefore, on a risk based approach, relevant evidential documentation must be requested where a change in circumstances in respect of their trading patterns, amounts and currencies, frequency or recipients occur.

  6. 7.6. Service Risk

    Determining the money laundering risks of services should include a consideration of such factors as services identified by regulators, governmental authorities or other credible sources as being potentially high risk for money laundering.

    The Company has established non-acceptable use policy which to clearly indicate the business models which are not among the acceptable ones. Those include, but are not limited to:

    • Material which incites or promote violence and/or racism;
    • Any goods or services that infringe on the intellectual property rights of third parties;
    • Prepaid or other stored value cards that are not associated with a particular merchant and/or are not limited to purchases of particular products or services;
    • Unlicensed gambling services of any type.
  7. 7.7. Record Keeping

    Record-keeping is an essential component of the audit trail required to assist in any investigation. Records must be kept of all documents obtained for the purpose of customer identification (KYC policy requirements) and all data of each transaction as well as other information related to money laundering matters in accordance with the applicable anti-money laundering laws/regulations. That includes files on suspicious activity reports, documentation of AML account monitoring, etc. Those records must be kept for a minimum of 5 years.

8. Non-compliance

Any Company’s employee or contractor, who violates this Policy may be subject to appropriate disciplinary action, independently from potential other penalties resulting from their behaviour.

Internal audit shall conduct regular checks on business to ensure compliance with AML Laws.

9. Updates, Review and Ownership

This Policy may be updated from time, and the updated version of the Policy will be immediately made available on the Company’s web-site.