KYC/AML/CFT POLICY

1. GENERAL PROVISIONS

1.1. This KYC, AML and CFT Policy (hereinafter referred to as the «Policy») governs the relationship between the company Verlos SIA:
registration No.: 40203344939;
date of Incorporation: 10.09.2021;
legal address: Nomales iela 7 - 6, Rīga, LV-1002;
email: [email protected]

(hereinafter referred to as the Company), and you, hereinafter referred to as the "User", for using the computer program (hereinafter referred to as the «Service»), under the following conditions:

2. TERMS AND DEFINITIONS

2.1. AML (Anti-Money Laundering) — procedures for prevention of laundering proceeds of crime.

2.2. CFT (Countering Financing of Terrorism) — procedures for countering the financing of terrorism and the financing of proliferation of weapons of mass destruction.

2.3. FATF (The Financial Action Task Force on Money Laundering) — an intergovernmental organization that develops international standards in combating money laundering and terrorist financing AML/CFT, and also conducts assessments of national compliance AML/CFT systems with these standards.

2.4. KYC (Know Your Customer) — «Know Your Customer» procedures.

2.5. Automated processing of personal data is the processing of personal data by means of computer technology (computer).

2.6. Blocking of personal data is a temporary cessation of personal data processing (except where processing is required for personal data refinement).

2.7. Internal control — the activity of Company is aimed at the detection of transactions subject to mandatory control and other transactions in amounts of money or other property that are related to the legalization (laundering) of the proceeds of crime and the financing of terrorism and the financing of proliferation of weapons of mass destruction.

2.8. Information access is the ability to obtain and make use of information.

2.9. Information is details (messages, data) regardless of the form of their presentation.

2.10. Confidentiality of information is a mandatory requirement for a person who has access to certain information not to disclose it to a third party without the owner’s consent.

2.11. Computer — the operating system, virtual machine or hardware, including the workstation, mobile device or server for which the Software is intended and/or on which the Software is to be installed and/or on which the Software is to be used.

2.12. Personal Account is a single personal part of the Service that provides the functionality: (1) of the User individualizing among other Users of the Service; (2) implementation by the User of the rights to use computer Programs and information on the terms and pursuant to the conditions set out in the Agreement; (3) of exchange of data, information and messages between the User and the Company; (4) for the Company to monitor the progress of the User's right to use Computer Programs and information. Access to the Personal Account and its functionality is provided to the User after registration on the Service.

2.13. Depersonalization of personal data means actions making it impossible to identify a connection between personal data and a specific data subject without using additional information.

2.14. Personal data processing — any action (operation) or a combination of actions (operations) performed both automatically and manually with personal data, including collection, recording, arrangement, accumulation, storage, specification (updating, changing), extraction, use, distribution (including transfer), anonymizing, blocking and destruction of personal data

2.15. Personal data means any information referring directly or indirectly to the User (personal data subject).

2.16. User means any individual:

(1) with full capacity to act;

(2) who is one of the parties to this Policy;

(3) who has the necessary legal capacity to gain access to the Service and implement the capabilities provided by the functionality of the Service;

(4) who is the holder of a Personal Account;

2.17. The Rightholder (the owner of the exclusive right to the Service) — the Company. 

2.18. Provision of personal data — actions related to making the data available to a definite person or a definite range of persons.

2.19. Distribution of personal data — actions related to making the data available to indefinite range of persons.

2.20. Service (a website located at https://verlos.ai) is an Internet resource consisting of a set of intellectual property objects of the Company (including the graphical interface (design) and information (Content) posted by the Company and/or Users.

The Service is contained in the information system that ensures the availability of such information on the Internet at the network address (domain name): https://verlos.ai (including all levels of the specified domain, both functioning as of the date of acceptance by the User of these Rules, and launched and entered in operation during the whole term of its operation).

Access to the Service is possible using the website, the mobile version of the website. 

2.21. Cross-border transfer of personal data means the cross-border transfer of personal data to a foreign state agency, foreign legal entity or individual located in a foreign state.

2.22. Destruction of personal data means actions performed on personal data contained in the respective database that prevent such data from being restored and (or) actions aimed at the physical destruction of the tangible medium of personal data.

2.23. Account is a data set about a user stored on the Service, necessary for identification (authentication) and providing access to the User’s personal data and settings.

3. ARRANGEMENT OF THE INTERNAL CONTROL SYSTEM

3.1. The main objective of internal control is to prevent any involvement of the Company's employees, as well as Users, into the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of proliferation of weapons of mass destruction.

3.2. Measures aimed at countering the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of proliferation of weapons of mass destruction:

(1) arrangement and implementation of internal control;

(2) mandatory control;

(3) prohibition on informing Users and other persons about the measures taken to counter the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of proliferation of weapons of mass destruction, except for informing Users on termination (suspension) of transactions, on necessity to produce documents on the grounds provided by the applicable legislation and this Policy;

(4) other measures taken under the applicable legislation and regulations adopted in compliance with it;

3.3. The management and employees of the Company, as well as Users, shall comply with the full implementation of the measures specified in Clause 3.2 hereof, subject to the following requirements: 

(1) participation of all employees of the Company in arrangement and implementation of the internal control process, regardless of their position to the extent of their functions;

(2) maintaining the confidentiality of information disclosed during the implementation of internal control;

(3) prevention any involvement of the management and employees of the Company, as well as Users, into the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of proliferation of weapons of mass destruction;

(4) a ban on informing Users and other persons about the measures taken to counter the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of proliferation of weapons of mass destruction, except for informing Users on termination (suspension) of transactions, on necessity to produce documents on the grounds provided by the current legislation and this Policy;

(5) the data confidentiality of the Company's internal documents aimed at countering the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of proliferation of weapons of mass destruction;

(6) ensuring the completeness and timeliness of submission of information to authorized government bodies stipulated by the applicable legislation;

(7) the application of effective risk assessment procedures related to the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of proliferation of weapons of mass destruction.

3.4. A special officer (AML Officer) is appointed by the Company to be responsible for the implementation of the internal control rules, in the event that such a person is not appointed, the responsibilities of a special officer are assigned to the Chief Executive Officer.

In case of temporary absence of the Chief Executive Officer and/or AML Officer, its responsibilities are assigned to another person, taking into account the requirements imposed on the AML Officer.

3.5. Eligibility requirements for an AML Officer are as follows:

(1) possession of the sufficient knowledge, skills and abilities in the areas of preventing money laundering and financing of terrorism (The Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT));

(2) the absence of an unexpunged or unspent conviction for the commission of the economic crime

(3) independence from the Company's operating activities, acquisition of income, business development of the Company;

(4) interaction with the Company management on a regular basis (if necessary, having direct access to the top management of the Company) to ensure that the Company takes sufficiently effective measures to protect itself from risks;

(5) impartiality and fairness in the work performance and resistance to the pressure;

(6) being in the country of the Company’s registration

(7) having knowledge of international and national law of the funds exchange and transfer, AML/CFT, as well as the Company's KYC, AML and CFT policy;

(8) having the desired and sufficient level of authority to ensure that their duties are performed effectively, including for timely receipt of all necessary and requested information;

(9) formation and recruitment of employees in an required quantity to carry out their powers;

(10) having access to information on the movement of funds and funds transfer;

3.6. Functions, powers, responsibilities imposed on an AM Officer are as follows:

(1) developing and submission for approval internal control rules to the Company's management in order to counteract the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of proliferation of weapons of mass destruction;

(2) implementation of the internal control rules;

(3) preparation of guidance materials (if necessary), advising the senior management and the staff of any issues that have arisen during the implementation of internal control procedures;

(4) Providing training to the senior management and/or the staff of the Company on countering the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of proliferation of weapons of mass destruction;

(5) arranging and submission of information to the state supervisory authorities in accordance with the applicable legislation;

(6) submitting at least once annually a written report to the senior management on the results of the implementation of internal control rules and programs aimed at countering the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of proliferation of weapons of mass destruction;

(7) work management in accordance with the program of suspension of transactions with money or other property and the present Policy;

(8) involvement in the improvement of internal control rules and programs in order to counteract the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of proliferation of weapons of mass destruction; 

(9) development of the restated version of the Internal Control Policy an rules in case of amendments to the current AML/CFT legislation;

(10) ensuring the confidentiality of information obtained in the exercise of its functions;

(11) ensuring the appropriate storage and preservation of recorded information;

(12) providing law enforcement authorities with information as required under the applicable laws and the internal regulations;

(13) other functions under this Policy and internal control documents;

3.7. In order to perform these functions, an AML Officer and/or a special official shall also be entitled:

(1) to receive information and documents from the senior management and/or employees of the Company, including organizational and administrative documents, payment and account documents in accordance with the procedure established by the Policy;

(2) to make copies of the received documents, including obtaining and storing copies of files, copies of any records stored in local information networks and autonomous computing systems in accordance with the procedure established by the present Policy;

(3) to receive clarifications from the senior management and/or employees of the Company regarding the implementation of this Policy and internal control rules;

(4) to interact with law enforcement authorities, which are involved in the prevention of money laundering, terrorist financing and other illegal activities;

(5) to exercise other rights under the Company's internal control documents for the purposes of anti-money laundering and countering the finance of terrorism.

4. IDENTIFICATION PROCEDURE

4.1. Before providing the User with access to the Service payment systems, the Company shall be obliged to identify him/her by obtaining the following information:

(1) in regard to individuals — surname, first name and patronymic (unless otherwise required by the law or national custom), nationality, date of birth, identity document details, Taxpayer Individual Number (if any), as well as other information to confirm the indicated data;

(2) in regard to legal entities — the name, organizational and legal form, registration number, place of registration and legal address;

(3) in regard to a foreign unincorporated entity — name, registration number (numbers) (if any) assigned to the foreign unincorporated entity in the state (on the territory) of its registration (incorporation) during registration ( incorporation), code (codes) (if any) of the foreign unincorporated entity in the state (on the territory) of its registration (incorporation) as a taxpayer (or their equivalents), place of principal business activities, and assets under management (owned), surname, first name, patronymic (if any) (name) and place of residence (place of business) of founders and trustee (manager) – applicable to trusts and other foreign unincorporated entities with similar structure or function.

4.2. Identification of the User, the user representative and (or) the beneficiary (hereinafter referred to as «Users») includes the following activities:

(1) identification of the user personal data and confirmation of the accuracy of this information prior to providing the User with access to Service payment systems;

(2) verification of the existence or absence of the personal data of Users:

— in the list of organizations and individuals in relation to which there is information about their involvement in extremist activities or terrorism;

— in the list of organizations and individuals in relation to which there is information about their involvement in the proliferation of weapons of mass destruction;

— in decisions on the freezing (blocking) of funds or other assets issued by the authorized bodies taking measures to counter the financing of terrorism;

— in the risk-assessment and assignment of the hazard rate (level) to the User;

— in revealing of public officials and their relatives;

— in revealing of persons from countries that fail to comply with the Financial Action Task Force (FATF) requirements;

— in updating data obtained as a result of User identification, verification and identification of beneficiaries;

(3) determination of the financial and economic activity goals, financial position and business standing of Users;

(4) ascertainment sources of the origin of funds and assets with which transactions are carried out;

(5) updating the User information at least once annually;

(6) updating of data within seven working days if any doubts arise about the reliability and accuracy of previously received information;

(7) storing and submission of the obtained information to the state supervisory authorities;

(8) the User's access lockout to the payment systems of the Service if the User is identified in the list of organizations and individuals with respect to which there is information about their involvement in the proliferation of weapons of mass destruction;

4.3. The Company shall take reasonable and accessible measures to collect information and documents proving that the User is acting in his / her own interests or in the interests of another person (beneficiary), including on the basis of an agency agreement, a commission agent agreement, a contract of delegation, a trust management agreement, during transactions, as well as based on the identification of beneficiary.

4.4. The Company shall verify the User identity on the basis of documents that contain valid and current information allowing the User to be identified. 

4.5. The Company shall perform identification based on the following identity documents of Users:

(1) passport (national or travelling);

(2) international driver's license; 

(3) utility bills with address;

(4) other documents. 

4.6. Users shall be required to provide self-portrait photographs (selfies) with their passport and upload the photos to their Personal Account.

4.7. The Company shall have the right to require Users to provide original documents or duly certified copies for examination.

4.8. The Company shall restrict the use of the Service to citizens and/or residents from the countries listed in Appendix No.1 of the Policy.

5. IDENTITY VERIFICATION PROCEDURE

5.1. The procedure of the identity verification of Users provides for carrying out group of actions aimed at obtaining information about such Users, as well as business standing of Users (assessment of the User based on publicly available information).

5.2. To verify the authenticity of documents and information provided by Users, the Company applies available legal measures and means. 

The Company reserves the right to collect the Information about Users whose identities have been identified as dangerous or suspicious. 

5.3. The Company reserves the right to verify the identity of Users on an ongoing basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User).

5.4. The Company shall be entitled to request up-to-date documents from the Users, even though they have passed identity verification in the past. 

5.5. After Users verification and identification, the Company shall have the right to refuse to provide Users access to the Service if it is used or is likely to be used to carry out illegal activities.

6. BANK CARD VERIFICATION

6.1. Users are required to pass verification procedure according to the rules posted on the Service if they intend to make payments by using bank cards.

7. RISK ASSESSMENT PROCEDURE

7.1. The Company assesses and assigns a risk rating (level) to Users at the moment of their identification, as well as verification in the Service.

(1) The risk assessment is carried out by the Company both before providing the User with access to Service payment systems and during the use of the Service.

(2) Risk assessment is implemented by the Company with one or a combination of the following categories:

— risks associated with Users;

— risks associated with the use of the Services by Users;

— risks associated with countries and separate geographical territories.

(3) The risk evaluation of Users are classified according to the following risks assessments (levels):

— Low-risk;

— Moderate-risk;

— High-risk.

(4) By taking into account the signs of transactions, the type of business activities of the User that having an increased risk of carrying out for the purpose of money laundering and the finance of terrorism (hereinafter referred to as "categories of high-risk assessment (level)), the Company undertakes an appropriate risk assessment of each User based on the requirements of the state supervisory authorities, and in line with the recommendations of the Financial Action Task Force (FATF).

7.2. An approximate list of the signs of transactions, the type of business activities of the User that having an increased risk of carrying out for the purpose of the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of proliferation of weapons of mass destruction is set out in Appendix No.2 to the Policy.

7.3. If the transactions or activities of Users are categorized into high-risk level, the Company pays increased attention to the transactions performed by these Users to reveal the grounds for documenting information that fall under the category and signs of suspicious user transactions in accordance with the internal control rules, and in order to submit information about the transactions to the authorized government body.

7.4. According to the results of analysis of user date and transactions performed by Users or in the interests of Users obtained by the Company, a subjective judgement is made to assign a risk category (level) to Users.

7.5. The Company shall monitor a risk degree (level) assigned to Users on the regular basis.

The Users who have, for a long time, been using the Service are assessed based on the factors of a risk degree (level) is assigned to them.

Revising decision of the degree (level) of risk determined to Users is made on the basis of risk assessment factors.

7.6. The risk assessment (reassessment) level, as well as the grounding for the risk assessment (reassessment) are recorded in the System by the Company.

7.7. The Company’s management and/or an employee may provide for the internal rules a different way of documented procedure of the risk assessment (level) and justification for risk assessment.

8. TRANSACTION VERIFICATION PROCEDURE

8.1. The Company shall monitor User transactions on an ongoing basis to identify transactions subject to mandatory control.

8.2. The Company carries out the identification of transactions, based on the criteria and signs of unusual transactions according to Appendix No.3 to the Policy. 

8.3. The Company shall pay close attention (monitoring) to the operations (transactions) of Users classified as a high-risk group in order to identify suspicious transactions, the implementation of which may be aimed at the legalization (laundering) of proceeds of crime or the financing of terrorism and the financing of the proliferation of weapons of mass destruction.

8.4. In order to determine whether a transaction related to suspicious transactions performed for the purpose of the legalization (laundering) of proceeds of crime or the financing of terrorism, the Company shall take into account the criteria and signs of unusual transactions contained in Appendix No.3 to the Policy.

8.5. By identifying signs of a suspicious operation (transaction), the Company shall examine other operations (transactions) of the User to confirm the grounded of suspicions that the User is involved in an operation (transaction) or a number of operations (transactions) for the purpose of the legalization (laundering) of proceeds of crime or the financing of terrorism.

8.6. If an unusual operation (transaction) or its signs are detected in the User's activity, the Company shall also take the following measures: 

(1) to request the necessary clarifications including additional information from the User in order to explain the economic rationale of an unusual operation (transaction);

(2) to provide thorough examination (monitoring) of all operations (transactions) of this User in accordance with this Policy and the requirements of legislation in the field of countering the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of proliferation of weapons of mass destruction;

(3) to take other necessary measures, subject to any requirements specified by law;

8.7. Based on the results of an operation (transaction) monitoring, the Company's management or an Anti-money laundering Officer (ALM Officer) is made decision on:

(1) the recognition of the User's operation (transaction) subject to mandatory control under the Policy;

(2) on the recognition of an identified unusual operation (transaction) as a suspicious transactions (transaction), the implementation of which may be aimed at the legalization (laundering) of proceeds of crime or the financing of terrorism and the financing of the proliferation of weapons of mass destruction;

(3) the need for taking additional measures to monitor an unusual operation (transaction) of the User;

(4) the submission of transactional information stipulated in Subparagraphs «1» and «2» of this Paragraph to the authorized government bodies.

8.8. The Company records information according to the detecting program of user transactions, when identifying signs of carrying out:

(1) operations (transactions) subject to mandatory control in accordance with Appendix No.2 to the Policy;

(2) operations (transactions) that fall under the criteria for detecting and (or) signs of an unusual operation (transaction);

(3) another operation (transaction) which raised suspicion that it is performed with the aim of the legalization (laundering) of proceeds of crime or the financing of terrorism.

8.9. Information must be documented on the basis of data and documents provided by Users. The documents allowing to identify the User, the beneficiary and other participants of the operation (transaction), as well as to define the grounds for transactions, must be valid and current.

Information about the User, as well as the user operations (transactions) are documented by the Company in a way that allows, if necessary, to reproduce the details of the operation (transaction), including the amount of the operation (transaction), transaction currency and details of payment, as well as data of the User's counterparty.

8.10. The Company reserves the right:

(1) to submit information about suspicious transactions to the supervisory authorities by the AML Officer;

(2) to request the User to provide any additional information and documents in case of suspicious transactions;

(3) suspend or terminate User’s Account when Company has reasonably suspicion that such User engaged in illegal activity;

8.11. The Company shall be obliged to report to the authorized supervisory bodies about transactions in the Service that are being performed or may be performed with the aim of the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of proliferation of weapons of mass destruction.

9. FREEZING (BLOCKING) PROCEDURES

9.1. The Company shall be entitled to freeze the user transfer of funds, as well as block access to the payment systems of the Service, if the funds have been received by the User from third parties and/or sent to third parties included:

(1) in the list of the organizations and individuals, in respect of which there is evidence of their involvement in extremist activities or terrorism or

(2) in the list of the organizations and individuals, in respect of which there is evidence of their involvement in the proliferation of weapons of mass destruction,

(3) or organizations or individuals, in respect of which there are sufficient grounds to suspect their involvement in terrorist activities (including the financing of terrorism) in the absence of grounds for inclusion in these lists.

9.2. Freezing (blocking) measures means the creation of conditions under which persons included in the above mentioned lists, as well as persons in respect of which freezing (blocking) measures are applied, are denied the opportunity to receive and (or) dispose of funds, and (or) assets (including property income, such as interest on deposits, dividends, and other property income of these persons).

9.3. After making a decision to exclude a User from the lists, the Company shall remove the freezing (blocking) measures to the User.

10. TERRITORY AND TERM OF VALIDITY OF THE POLICY. MODIFICATION AND TERMINATION OF THE POLICY

10.1. The User shall have the right to use the Service within the available territories by means standard computer tools and programs.

10.2. The Policy comes into force upon the User makes the acceptance of the terms of the Policy, and IT shall be concluded for an indefinite period.

10.3. This Policy shall terminate if:

10.3.1. The User terminates the use of the Service by sending the appropriate notice to the Company (by contacting Technical Support via the Service interface, or by sending a scanned copy of the corresponding request to the email address of the Company specified in Clause 1.1 of the Policy);

10.3.2. The Company terminates this Policy under unilateral extrajudicial procedure with immediate termination of access and the ability to use the Service and without reimbursement of any expenses and damages unless otherwise provided by the applicable legislation. In particular, the Company may terminate the Policy in case of:

10.3.1. closure of the Service

10.3.2. any, including single, violation by the User of the terms of this Policy;

10.4. The Company shall be entitled to unilaterally make changes and / or additions to the Policy at any time without given reasons. Any modifications and additions to the Policy are unilaterally made by the Company come into force on the next day of posting on the website. The user undertakes to independently check the Policy for changes. The User undertakes to independently check the Policy for changes. The User's failure to get acquainted with the Policy and/or the revised versions thereof shall not give rise its failure to fulfill the obligations and observe the limitations stipulated herein.

10.5. Actual use of the Service by the User after the amendments are made to the terms of this Policy means that the User agrees with the new terms.

Edition dated January 22, 2022

Appendix № 1 to the Policy

List of countries subject to restrictions on the use of the Service

1.1. The Company does not provide services (does not provide access to the Service) to citizens and/or residents of the following countries:

— Anguilla (AIA)

— Afghanistan (AFG)

— Burkina Faso (BFA)

— Guinea-Bissau (GNB)

— Democratic Republic of the Congo (COD)

— Zimbabwe (ZWE)

— Liberia (LBR)

— Lebanon (LBN)

— Libya (LBY)

— Iran (IRAN)

— Iraq(IRQ)

— Yemen (YEM)

— NORTH KOREA (PRK)

— Colombia (COL)

— Côte d'ivoire (CIV)

— Kuwait (KWT)

— Mali (MLI)

— Mozambique (MOZ)

— Myanmar (Burma) (MMR)

— Nigeria (NGA)

— Rwanda (RWA)

— Sierra Leone (SLE)

— The United States of America (USA)

— Somalia (SOM)

— Sudan (SDN)

— Philippines (PHL)

— Central African Republic (CAF)

— Eritrea (ERI)

— Ethiopia(ETH)

1.2. The Company shall have the right to make changes and/or additions to the list of countries specified in Paragraph 1.1 of Appendix No.1 to the Policy under the AML/CFT Principles and this Policy.

Edition dated January 22, 2022

Appendix № 2 to the Policy

The list of the signs of transactions, the type of business activities of the User that having an increased risk of carrying out for the purpose of the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of proliferation of weapons of mass destruction

— Activities related to the organization and conduct of gambling.

— Activities related to the sale, including commission, of art, antiques, high-priced luxury items.

— Activities related to the purchase, the buying and selling of precious metals, precious stones, as well as jewelry containing precious metals and precious stones, and precious metals scrap.

— Activities related to transactions with real estate and /or the brokering in real estate transactions. 

— Any activity related to large volumes of cash turnover

— The period of activity of the legal entity from the date of registration is less than 1 (one) year.

— The User registration period on the Service is less than 6 (six) months.

— Absence of the head of the permanent management body of a legal entity, other bodies or persons entitled to act on behalf of a legal entity without a power of attorney at the address of the location of the legal entity.

— Users interact with the Company exclusively through a representative acting by proxy.

— The User is an organization in the authorized capital of which there is a share of state ownership.

— The User is a foreign public official or acts in the interests (for the benefit) of a foreign public official.

— The client is a spouse, a close relative (a relative in a direct line ascending and descending line (parent and child, grandfather, grandmother and grandson), a full and incomplete (having a common father or mother) brother and sister, adoptive parent and adopted) of a foreign public official.

— An transaction in funds or any other assets performing by the Client is subject to compulsory control, if the amount on which it is completed is equal to or exceeds 3,000,000 EUR, or the amount of foreign currency equivalent to 3,000,000 EUR.

— Existence of suspicious transactions in the activities of Users, about which information is submitted to the authorized authority.

— Users are involved in the list of the organizations and individuals, in respect of which there is evidence of their involvement in extremist activities.

— The registration address (location or place of residence) of Users coincides with the registration address (location or place of residence) of the persons involved in the list of the organizations and individuals, in respect of which there is evidence of their involvement in extremist activities.

— The user is a close relative of a person included in the list of organizations and individuals, in respect of which there is evidence of their involvement in extremist activities or terrorism.

— The User is the head or founder of a public or religious organization (association), a charitable foundation, a foreign non-profit non-governmental organization, its branch or representative office.

— The user is registered in a state or territory with high terrorist or extremist activity.

— The User has, respectively, registration, place of residence or place location in the state (territory), which does not meet the recommendations of Financial action task force on money laundering (FAT) or if the transactions are performed using the bank account registered in the specified state (on the specified territory).

— The User is registered or operates in a state or territory providing preferential tax treatment and (or) not providing for the disclosure and provision of information during financial transactions (offshore zones).

— Other signs for the discretion of the Company.

Edition dated January 22, 2022

Appendix № 3 to the Policy

Criteria and attributes of unusual transactions

General criteria for unusual transactions

— The unusual nature of transactions that makes no obvious economic sense or have no obvious legitimate purpose is discovered.

— Non-compliance of transactions with the objectives of the organization’s activities established by the organization founding documents.

— Repeated operations or transactions that give reason to believe that the purpose of their implementation is to avoid the mandatory control established by the applicable legislation.

— The User's refusal to provide the requested documents and information that the Company needs to meet the requirements of legislation in the field of countering the legalization (laundering) of proceeds of crime and the financing of terrorism.

— Excessive concern of the User about confidentiality of the operation (transaction), including disclosure of information to government authorities.

— The presence of non-standard or unusually complicated schemes (instructions) according to performing calculations that differ from the usual practice used by these Users, or from the standard market practice.

— Unreasonable haste in carrying out the transaction requested by the User.

— Essential changes, especially concerning the movement of funds or other assets in the previously agreed operation (transaction) scheme, made immediately prior to transaction implementation by the User.

— Transfer by the User of a request for performing a transaction through a representative (intermediary), if the representative (intermediary) carries out the client’s order without entering into direct (personal) contact with the Company.

— A clear discrepancy between the transaction carried out by the User with the participation of the organization, the generally accepted market practice of performing transactions.

— Lack of information about the User - a legal entity in official reference publications, or the inability to communicate with the User at the addresses and phone numbers indicated by the User. 

— Difficulties encountered by the Company when verifying the User information, unreasonable delays in the provision of documents and information by the User, the providing information cannot be verified.

— Operation (transaction) where the User is a foreign public official or an official of a public international organization, or acts in the interest (for the benefit) of a foreign public official, or is a spouse, a close relative (in a direct line ascendant or descendant line (parent and child, grandfather, grandparent, grandchild or granddaughter), a full and incomplete (having a common father or mother) brother and sister, adoptive parent and adopted) of a foreign public official.

— Performing an operation (transaction) when the User acts on behalf of (in the interests of) non-profit organizations, foreign non-profit non-governmental organizations and their branches, representative offices and subsidiaries.

— Performing an operation (transactions) in the case when the User is the head or founder of a non-profit organization, a foreign non-profit non-governmental organization, its subsidiaries, branch or representative office.

— Operations (transactions) involving of art objects.

— Performing an operation (transactions) in the case when the User is a non-profit organization, a foreign non-profit non-governmental organization and its branch, representative office and affiliate.

— The operation (transactions) by the User, in respect of whom the authorized state body sent a corresponding request to the Company.

— The User's refusal to perform a one-time transaction which raised suspicion by the Company's employees that it is performed with the aim of the legalization (laundering) of proceeds of crime or the financing of terrorism.

— User's account, which is different from the account from which these funds were previously credited, including to an account with a non-resident bank, or to their own account of another bank or to the account of a third party.

— Receiving funds from a User - a legal entity whose founders include charitable organizations and/or foundations or other types of non-profit organizations with a share in the authorized capital of such a person, allowing directly or indirectly to have influence on the decisions taken by the specified legal entity.

— Receiving funds from the User if there are grounds to believe that the User is a recipient of grants or other types of gratuitous financial assistance from foreign non-profit non-governmental organizations and / or their representative offices and branches.

— Transactions using remote service systems, if there is a suspicion that such system are used by only a third party.

— A significant deviation of the transaction amount relative to the current market prices, including at the insistence of the User.

— Performing operations (transactions) with a legal entity whose period of activity from the date of registration is less than 1 (one) year.

— An operation to receive or provide gratuitous financial assistance in an amount not exceeding 3,000,000 EUR or its equivalent in foreign currency.

— Operation (transaction) in the interests of a User whose period of activity since the registration of a legal entity does not exceed 3 (three) months, while the client has an insignificant amount of authorized capital compared to the amount of the operation (transaction) that he / she intends to commit.

— Other criteria. 

Edition dated January 22, 202