ANTI-MONEY LAUNDERING, COUNTER-TERRORIST FINANCING AND KNOW YOUR CUSTOMER POLICYLast Revised: 25.11.2019
The purposes of the SFOR.INFO’s Anti-Money Laundering and Counter-Terrorist Financing Policy and Know Your Customer Policy (hereinafter - the “AML/CFT and KYC Policy”) is to identify, prevent and mitigate possible risks of SFOR.INFO being involved in illegal activity.
In conformity with international and local regulations, SFOR.INFO implements effective own internal procedures and instruments to prevent money laundering, terrorism and crime financing, illegal transfer of assets, drug, human, organ and any other illegal trafficking, poaching, pornography, trade in arms, corruption and bribery, and to react correspondingly in case of any form of suspicious activity from its Users.
This Policy includes verification procedures, compliance officer, monitoring of transactions, risk assessment.
One of the international standards for preventing illegal activity is customer due diligence. According to customer due diligence, SFOR.INFO establishes its own verification procedures within the strict standards of anti-money laundering, counter-terrorist financing procedures and “Know Your Customer” frameworks.
SFOR.INFO identity verification procedure requires the User to provide SFOR.INFO with reliable, independent source documents (for example, a national ID card or international passport). For such purposes, SFOR.INFO reserves the right to collect User’s identification information for the purposes of the AML/CFT/KYC Policy.
SFOR.INFO will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and SFOR.INFO reserves the right to investigate the cases of certain Users whose identities have been identified as dangerous or suspicious.
SFOR.INFO reserves the right to verify the identity of the User on an ongoing basis, especially when its identification information has been changed or its activities appear suspicious (unusual for a particular User). SFOR.INFO can identify an activity as suspicious on its sole discretion.
SFOR.INFO reserves the right to request up-to-date documents from the Users, even if they have been authenticated in the past.
After confirming the identity of the user, SFOR.INFO may refuse to provide services to the User if SFOR.INFO’s services are used for the purposes of conducting illegal activities.
implementation and enforcement of the AML/CFT/KYC Policy.
It is the Compliance Officer’s responsibility to supervise all aspects of SFOR.INFO’s anti-money laundering and counter-terrorist financing procedures, including but not limited to:
- Collecting Users’ identification information;
- Establishing and updating internal policies and procedures for the completion, review, submission, and retention of all reports and records required under the applicable laws and regulations;
- monitoring the transfer of assets and investigating any significant deviations from normal transfer activity;
- Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs;
- Updating risk assessment regularly;
- Interact with competent authorities, involved in the prevention of all types of illegal activity.
Monitoring of transactions
The Users can be known not only by verifying their identity (who they are) but, more importantly, by analyzing their assets’ transferring patterns (what they do).
Therefore, SFOR.INFO relies on data analysis as a risk-assessment and suspicion detection tool. SFOR.INFO may perform a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting.
Monitoring system functionalities may include:
- Aggregating transfers of assets by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
- Case and document management.
With regard to the AML/KYC Policy, SFOR.INFO will monitor all transactions and it reserves the right to:
- Ensure that transactions of suspicious nature are reported to the proper competent authority through the Compliance Officer;
- Request the User to provide any additional information and documents in case of suspicious transfers of assets;
- Suspend or terminate User’s Account when SFOR.INFO has a reasonable suspicion that such User engaged in illegal activity.
However, the above list is not exhaustive and the Compliance Officer will monitor the transactions of the users on a regular basis to determine whether to report such transactions and treat them as suspicious or should be considered conscientious.
Payment and transactions processing
SFOR.INFO strictly prohibits using the Service through anonymous proxy-servers, or any other anonymous Internet connections.
In order to prevent possible unlawful transactions SFOR.INFO requires the sender of the payment must be the same person as the payee. Any payments in favor of a third party are strictly prohibited.
SFOR.INFO, in line with the international requirements, has adopted a risk-based principle to combating money laundering and terrorist financing. This makes SFOR.INFO to be able to ensure that measures to prevent an illegal activity are commensurate with the identified risks. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.