This Anti-Money Laundering and Know Your Customer Policy (hereinafter, the AML/KYC Policy) is designated to prevent the use of Company’s services for Money Laundering and Terrorist Financing, and evading or violating economic sanctions.
Please read this AML/KYC Policy carefully before using our website and our Services. You should read and understand it before accessing the Services, because this AML/KYC Policy is one of the documents that allow correct and safe use of the Services.
Our AML/KYC Policy, procedures, and internal controls are designed to ensure compliance with all applicable regulations and rules and will be reviewed and updated on a regular basis to account for both changes in regulations and changes.
The Company may share the information received as a result of the AML/KYC procedure with the legal authorities if provided a legitimate official request.
The Company will never go for any agreement with an individual or entity alleged of or directly involved in money laundering or in which the funds sourced from illegal activities.
The Policy covers the following matters:
1. Appointing an Anti-Money Laundering Compliance Officer (AMLCO) and making sure that employees know to report any suspicious activity to them. The AMLCO’s responsibility is to implement and effectively monitor the application and enforcement of the AML/KYC. The AML Compliance Officer is obliged to oversee and conduct effective monitoring of all aspects of Company’s anti-money laundering and counter-terrorist financing.
2. Whenever the Company receives supporting documents related to a new Translator’s identity, it needs to be completely satisfied that they demonstrate the existence of the new Translator as a real natural or legal person and that they are indeed whom they say they are.
All participants of Company transactions shall provide AML Compliance Officer with:
– Identity Proof, such as Passport or Driving License;
– Address Proof, such as Passport, Electricity Bill, Bank Account Statement, Gas Bill, rent receipt, etc;
– Other necessary documents.
3. Recordkeeping. We will document our verification, including all identifying information provided by a translator, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process.
4. Monitoring of transactions. The constant monitoring of the Translators’ accounts and transactions is an imperative element in the effective controlling of the risk of Money Laundering and Terrorist Financing. The extent of monitoring will depend on the risk sensitivity of the account. High-risk accounts have to be subjected to intensified monitoring. In case of sudden swaps of big amounts, these accounts can be flagged by the risk scoring system as low, medium, or high risk
5. The criteria for the identification of suspicious/high risk transactions:
a. The Translator is reluctant to provide information necessary to establish their identity, conceals the identity or provides documents posing doubts on their veracity, authenticity, etc.
b. Receiving information or documents necessary for the identification from the Translator is difficult: it is difficult to contact the Translator, the Translator does not respond to email messages.
c. The Translator refuses to provide data on the origin of their funds involved in the transaction.
d. The Translator uses TOR network services, constantly connecting from IP addresses in different countries.
e. The Translator appears to be a resident of a high-risk region.
The Company is prohibited from transacting with individuals, companies and countries that are under international sanctions.
Sanctioned countries list:
Afghanistan, American Samoa, Angola, Bahamas, Botswana, Belarus, Burundi, Cambodia, Central African Republic, Chad, Congo, Cuba, Democratic Republic of Congo, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guam, Guinea Bissau, Iran, Iraq, North Korea, Lebanon, Libya, Mali, Nigeria, Pakistan, Panama, Puerto Rico, Russia, Samoa, Saudi Arabia, Sierra Leone, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Venezuela, Yemen, Zimbabwe, some states of the USA.