Procedures for Anti Money Laundering

Under money-laundering legislation there are essentially three obligations:

1. Identify and verify the customers (due diligence)
2. Review transactions that could reasonably be expected to be aimed at money laundering
3. Report suspected cases of money laundering

In addition:

• More due diligence and verification based on a risk-based approach (risk-based approach), including in the case of beneficial owner (beneficial ownership), people in vulnerable political positions known politically exposed person (PEP), and expanded documentation requirements is required
• Ongoing monitoring of customer relations (monitoring) for the risk assessment based on the risk profile of the client

"Risk-based approach"

The lowest risk required information is checking the customer's identity using the passport, driving license or equivalent and a second source, e.g. utility bill to confirm address. This is probably fine in 99% of the clients.

The high risk, less than 1% of the clients, means the most resources are applied where situations of money laundering risk are greatest. These possible clients could in certain situations require more accurate and in-depth due diligence than normal.

“Natural Owner’s identity” of the Company

The ultimate beneficial owner's identity of a company needs to be determined – i.e. the warm body. The ownership of a company should be investigated in the whole chain down to the natural person who ultimately owns the legal person. This should be investigated and identified no matter how long or wide chain is. "Beneficial owner" is also that which is future beneficiaries and holders of 25% or more of the assets managed by such a foundation.

To achieve the basic due diligence is also information about the customer order and end the business relationship sought. The reason for this is that the company should have a clear picture of what the company should provide and what the client's business is about. Often shows the object and purpose in a natural way already in the initial contacts with customers, but because of the risk-based approach to be used for business, more basic information need to be gathered to assess the risks of money laundering and terrorist financing. The current money laundering legislation is the ability of the Company to rely on information provided by third parties where this is already done action to obtain customer information.

High risk can be assumed when:

1. Data on the customer's identity is insufficient or not deemed to be reliable.
2. Uncertainties of basic due diligence remains.
3. Suspicions of money laundering or terrorism financing exist.
4. Business relationship includes transactions, services or products that may favor anonymity (e.g. use of cash).
5. The client is domiciled in, or transactions carried out in a country with a high risk of money laundering or terrorist financing (“high-risk country").

More information on high-risk countries can be found at FATF, www.fatf-gafi.org.

Customer not Present = higher risk

Additional documents, data or information may need to be gathered and verified or verification of the authenticity of such documents may be needed, such as specimen signatures of customers at a distance, and evidence of beneficial owner's identity.

The Customer shall keep the identity of the original document and copies saved. For foreign nationals carried out identity checks with the corresponding foreign document. Information about the client should routinely be searched via the Internet and use available major search engines to identify the person. Identity checks are carried out by a combination of information gathered from various independent sources.

Personal data relating to identity, citizenship, residence, place of residence and other official functions addressed within the system support that the company uses out of work on issues related to money laundering and terrorist financing. This is done for the Company to assess the customer.

The company's records may contain:

1. Name, personality, coordination and corporate identity and address information collected
2. Account numbers or the equivalent
3. Other information