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The role of the AML system in the fight against illicit money circulation, user identification, the use of financial sanctions in the framework of international relations .

1. Terms, abbreviations, as well as control measures of the state

1.1 Organization is an online resource on the Internet that provides currency exchange services in electronic and digital form.

1.2 User is a legal or natural person who cooperates with the Organization and orders certain services.

1.3 Illegal circulation of money is the laundering of funds, their concealment or misuse, as well as the concealment of persons and parties receiving money, transactions, transfers, finding, illegally obtaining funds, fraud.

1.4 Financing terrorist activities, investing groups of malefactors for their implementation of illegal actions that are punishable by criminal liability.

1.5 International sanctions are penalties imposed by the countries of the European Union, the UN and other international associations, governments of other countries in order to ensure peaceful cooperation and avoid conflicts.

1.6 Politically Vulnerable Person (PEP) is an individual who carries out a specific government activity. It can be a member of parliament, a minister, a head of state, and so on.

1.7 Local PEP - an individual (minister, deputy, head of state, member of parliament) who takes part in important state activities.

1.8 PEP family - a married couple, parents, children, relatives.

1.9 Close associates A PEP is a person who is in close relationship or business relationship with other persons.

1.10 The AML Law is the official regulation that regulates actions in relation to unlawful concealment of income.

2. Basic rules

2.1 This guide is based on the provisions of the current law on AML, as well as the regulation on the application and operation of international sanctions.

2.2 With the help of the manual (document), a number of effective measures are determined to establish the security of the internal organization in order to prevent and prevent illegal circulation of financial resources in the process of implementing transactions.

2.3 Persons who are part of the organization are instructed, the provisions of which all employees are guided in identifying and investigating misconduct and fraud.

2.4 Each addition and provision to the current law is considered and studied separately.

2.5 The Association of Founders develops and implements instructions and guidelines for employees of all parts of the organization.

2.6 After reading the instruction, the employee of the organization signs the corresponding writ of execution.

2.7 Employees of the Organization are individually responsible for compliance with the rules and regulations of the law.

3. User feedback, customer identification

3.1 Employees of the Organization, when carrying out activities in relation to communication with users of the portal, are guided by the relevant rules and regulations.

3.2 The organization cooperates with an individual directly, without intermediaries and representatives.

3.3 Identification of the user"s identity is carried out in accordance with the following provisions:

3.3.1 The identity of the client is verified and confirmed on the basis of the provided document (driver"s license, passport, passport, entry permit, and so on).

3.3.2 The following data is recorded and verified: Full initials of clients. Identification code, place of birth, date of birth, country and city of birth. Document series and number, date and issuing authority. Actual address of residence, address of official registration (propiska). Any contact information. Involvement of a person in PEP functions. Involvement of a person with a person (business partner or relative) who has the functions of a PEP.

3.3.3 Additional documents to be presented for personal identification: Residents of the state in which the service is located and operates must provide one of the following documents for verification and identification: international passports, driver"s license, passport, residence permit. Non-residents provide a passport, which must contain a mark of entry into the country. Documents confirming the official place of registration and residence. Additionally, you can present a utility bill, bank statement or any other document that clearly indicates the address of residence and registration of this person.

3.4 Documents that a legal entity must provide to identify a person:

3.4.1 Certificate issued by the Commercial State Registry (the date of its issue must be no later than 90 calendar days from the date of the request).

3.4.2 Additional information to check: Name of the legal entity (full, as in the statutory documentation). State registration number, date. Address (actual, legal). Data on co-founders, beneficiary (beneficiary). Contact details. For individuals who interact with a legal entity, it is necessary to provide one of the documents listed in paragraph 3.3.

4. Control measures and existing risks

4.1 Before starting official cooperation with the user of the resource, the organization calculates the possible risks in relation to the illegal circulation of financial resources in order to prevent the financing of terrorist groups.

4.2 Verification is carried out on the basis of the following categories:

4.2.1 Location and geography of activity.

4.2.2 Possible risks from the user.

4.2.3 Possible transactions requested by the user.

4.3 High risk for geographic information is possible if the user is active in the following regions:

4.3.1 Territories under European Union or UN sanctions.

4.3.2 Countries that do not carry out activities to prevent illegal circulation of funds.

4.3.3 States that sponsor terrorist groups and fraudulent activities, and where corruption is rampant.

4.3.4 Detailed information on high-risk countries can be found at .

4.4 A high risk from the user will be observed if:

4.4.1 The resource client is a PEP. This circumstance must be established before cooperation.

4.4.2 An individual is considered unreliable, or is included in the sanctions list of the European Union or the UN.

4.4.3 An individual is involved in illegal money laundering activities.

4.5 High risk from transactions will be observed if:

4.5.1 Financial coverage for the transaction is carried out by a third person not registered in the system.

4.5.2 There is no reasoned justification for concluding a transaction.

4.5.3 The list of participants is closed from public access.

4.5.4 Currency comes from different bank accounts.

4.5.5 The size of transactions is not specific to the user.

4.5.6 Each transaction is processed with different virtual currencies.

5. Prohibitions

5.1 In the event of sanctions being imposed on specific legal entities and civilians or on their countries of residence, the service will be forced to refuse cooperation.

6. States covered by the ban

6.1 In the case of residence of legal entities and civilians in the territory of countries that are included in the sanctions list due to money laundering, the service refuses to cooperate.