Anti Money Laundering and Terrorist Activity Financing Policy

  1. General Provisions

    1. Anti Money Laundering and Terrorist Activity Financing Counteraction Policy, hereinafter referred to as AML/TAFC Policy, is an integral and inalienable part of Client Agreement;
    2. The Altway Limited, hereinafter referred to as the Company, strictly observes the applicable international legislation on counteraction to income legalization (laundering), obtained through criminal means and terrorism financing;
    3. Within the AML/TAFC Policy, the Company has approved the Know Your Customer Policy, that expressed the continuous-flow analysis and monitoring of the Company’s Client and its’ activity on trading accounts;
    4. Within the AML/TAFC Policy, the Company has approved the Chargeback Policy;
    5. The main objectives of the AML/TAFC Policy are:
      1. creation of balanced AML/TAFC Policy principles and its’ reasonable implementation in such way to give early warning of Clients’ criminal activity on its’ trading accounts, while reducing its’ impact on law-abiding Clients;
      2. Maintenance of the Company’s business reputation safety;
      3. exclusion of the Company’s employees involvement and accomliceship in the income legalization, received through illegal way and terrorism financing.
    6. The AML/TAFC Policy establishes the general rules of internal control of the Client and is mandatory for all Company’s employees.
  2. General Principles of Anti Money Laundering and Terrorist Activity Financing Counteraction Policy

    1. The Company doesn’t open trading accounts for a anonymous owners;
    2. The Company have the right to block the enter to the Client’s Personal account, suspending the trading activity on the accounts, or cancel the application on funds deposit/withdrawal, if during the process of interaction between the Client (for legal entities; owners or chief executive) and the Company appears the data about the participation of the Client (its’ representatives) in the extremist activity or related to the money laundering activity;
    3. The Company doesn’t accept cash from the Clients as a deposit and doesn’t pay in cash under no circumstances;
    4. Use of the same payment details by different Clients of the Company is prohibited;
    5. Each Client of the Company is obliged to verify the payment details of their e-wallets in Clients Personal Accounts, that he intends to use for transactions on funds deposit and withdrawal;
    6. In case of doubts about the reliability and relevance of the data on the Clients payment details, the Company has the right to request the screenshot of the monitor with opened webpage of the payment system that include the information about this e-wallet owner;
    7. Funds within the Company can only be transferred between the accounts of the Client who passes the personal data verification procedure. The funds transfer between accounts and/or current accounts, that belongs to different Clients of the Company is prohibited;
    8. Funds can be withdrawn only by the same way and on the same payment details from which they were entered, unless the otherwise specified by the Company’s rules;
    9. The Company conducts mandatory verification of the Client in accordance to with the Client Agreement and according to the Know Your Customer Policy principles.
  3. Providing information to Authorized Bodies

    1. In case of detection of the Clients suspicious activity by means of its’ trading account, the Company’s employees are obliged to report to the Compliance Manager and send him all the necessary documents;
    2. Each employee of the Company is obliged to report to Compliance Manager on any suspicious propositions of the Clients, even if the operations wasn’t made;
    3. All actions taken in connection with the operations, reports about which are subject to submission to the authorized bodies, shall be documented and stored with the established requirements to safety of confidential information;
    4. The details of transactions, information about which are the subject to submission to the authorized bodies, and any contacts with the authorized bodies regarding these operations are documented.
  4. Confidentiality

    1. The information about the Clients and their operations, received within the context of AML/TAFC Policy principles is confidential;
    2. Company’s employees and Compliance Manager shall not inform the Clients and other persons about the forms, methods and techniques of AML/TAFC Policy principles implementation;
    3. Disclosure to other persons the information that the Company has been provided the authorized bodies with the information about the Clients operations and its’ activity is strictly prohibited.
  5. Data and Documents Storage

    1. The data received as a result of identification of the Client and the details of the transactions are stored as the evidence of the measures taken by the Company in accordance with present AML/TAFC Policy, as well as for their use as evidence during authorized bodies investigation;
    2. Identity details of the Client shall be stored at least five years after the termination of relations with the Client in accordance with the Know Your Customer Policy;
    3. The data on transactions, information on which was sent to the authorized body, shall be stored for at least five years from the date of the transaction;
    4. All inside and outside reports received within the AML/TAFC Policy principles implementation shall be stored at least five years from the date of report;
    5. The Company is obliged to keep information about all the actions, taken in connection with fulfillment of the requirements to receive from employees and submission to authorized bodies of information on the detected operations. In the event that there is decision to not send the information to authorized body on possible money laundering/terrorism financing, information about these facts is still the subject to storage.
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