AML / KYC policy
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AML / KYC policy

1. Goals

Money Laundering/Combating financing terrorism (AML / KYC / CFT) is the process of concealing financial
transactions to make illegitimate money, derived from illegal activities such as
embezzlement/corruption/illegal gambling/terrorism/organized crime, appear legitimate.
Under a broad definition, the laundering process is accomplished in three stages:
(a) Placement – the physical disposal of cash proceeds derived from criminal activity.
(b) Layering – separating the illicit proceeds from their source by creating complex layers of financial
transactions designed to disguise the audit trail and provide anonymity.
(c) Integration – the provision of apparent legitimacy to wealth derived from crime. If the layering process
is successful, integration schemes place the laundered proceeds back into the economy in such a way
that they re-enter the financial system appearing as normal business funds.
Its main objective is to hide the real source of illegal proceeds and make them legally usable, by converting
them into legitimate money through a series of financial transactions. Technological advancements have
helped money launderers adopt innovative means to transfer funds faster across continents making
detection and preventive action more difficult. The attempted misuse of the financial system for
perpetration of frauds has been recognized globally as a major problem that needs to be continuously
tackled at every level in a dynamic manner.
As a Responsible Company, we consider it our moral, social and economic responsibility to prevent the
misuse of the financial system for laundering proceeds of criminal activities and to coordinate the global
war against money laundering. Our role in curbing this global reality begins with stringent “Know Your
Customer” procedures.
Imbibing the true spirit behind the international financial community’s resolve to fight money laundering,
the Company has resolved to conduct day – to – day business with due skill, care and diligence and seek to
always comply with both the letter and the spirit of relevant laws, rules, regulation, codes and standards
of good practices.
The purpose of the Anti-Money Laundering/Combating financing terrorism measures is to prevent the
system of the Company from being used for money laundering and financing terrorism. Therefore, AML / KYC
and CFT measures formulated include:
1. Customer Identification Procedure – “Know Your Customer” procedures.
2. Monitoring of suspicious transactions.
3. Appointment of Compliance function.
4. Personnel Training.
5. Maintenance of Records.
6. Periodic testing of the implementation of AML / KYC / CFT and Compliance measures.

“Customer due diligence” (CDD) procedures include:
(a) Identifying a customer;
(b) Determining whether the customer is acting for a third party and, if so, identifying the third party;
(c) Verifying the identity of the customer and any third party for whom the customer is acting;
The scope of these procedures and policies applies to all branches, offices, contractors and affiliated
companies of the Company and is to be read in conjunction with related operational guidelines issued from time to time.
These procedures address the responsibility of management and employees for:
 Creating and implementing policies, procedures and controls related to customer’s acceptance,
maintenance and monitoring.
 Customer due diligence.
 Declining or terminating business relationships or transactions.
 Personnel training with regards to customer’s acceptance, maintenance and monitoring.
 Monitoring accounts, activities, policies, procedures and plans.
 Awareness and communication.
 Management reporting.
 Reporting (SAR/STR) to Financial Intelligence Unit (FIU).

Key Principles and Objectives

This procedure manual has the following key principles and objectives:
 The Company will introduce necessary policies and procedures to ensure that the risk of possible
money laundering, proliferation financing or financing of terrorism and related activities
associated with customers’ relationships and transactions is managed and mitigated.
 Customer due diligence procedures with regard to business relationships and transactions will be
developed and implemented as required by applicable legislation.
 To establish a business relationship with a potential customer, appropriate information has to be
obtained from the person seeking to establish the relationship. The information obtained is to be
verified by comparing it with information obtained from source(s) as required by legislation.
 The Company may decline or terminate business relationships or transactions where there
appears to be a risk that its services and infrastructure will be abused for the purposes of money
laundering and/or terrorist financing.
 The Company will provide the appropriate training to all affected employees on customer’s
acceptance, maintenance and monitoring.
 The Company will proactively monitor adherence to this procedures manual, ensuring compliance
with its obligations as required by legislation.
 Affected company employees must be made aware of the contents of this manual, inclusive of
their responsibilities and actions expected of them.

 Management reports must be produced to allow the company actively and effectively to monitor
customer’s acceptance, maintenance and monitoring initiatives.

2. Compliance function

Compliance function of the Company consists of two levels and addresses responsibilities of Money
Laundering Reporting Officer as well as Money Laundering Compliance Officer.
1. CEO (who also serves as Money Laundering Reporting Officer) and the Board of Directors of the
Company.
Responsibilities of the CEO and the Board of Directors include:
I. Create a culture within the Company that supports achievement of compliance objectives by
ensuring rigor in the recruitment, selection, individual development and monitoring of
compliance personnel.
II. Develop and promote, among Company’s personnel at all levels, high degree of awareness to the crucial importance of compliance with AML / CFT and KYC procedures.
III. Oversee the development, on-going update and implementation of compliance related policies and
procedures.
IV. Work in close collaboration with the Compliance department to ensure there is an effective
relationship between the Compliance department and the members of the Board.
2. Company’s Compliance department, headed by Chief Operational Officer (who serves as Money
Laundering Compliance Officer).
The Money Laundering Compliance Officer is responsible for:
I. Appointment of compliance officers (personnel of the Compliance department);
II. Monitoring, coordination and control over the day-to-day activity of compliance officers.
III. Training of compliance officers.
IV. Reporting to the CEO and the Board of directors of the Company if the Compliance department
has a reason to believe that a suspicious transaction has/ may have resulted in money laundering.
V. Periodic control of implementation of AML / KYC / CFT measures and compliance procedures.
VI. Periodic review and updating the present Manual.
Responsibilities of Compliance department include:
I. Putting in place necessary controls for detection of suspicious transactions.
II. Canceling or forbidding the transaction.

III. Receiving disclosures related to suspicious transactions from the staff or otherwise.
IV. Training of staff and preparing detailed guidelines/handbooks for detection of suspicious
transactions.

3. “Know your customer” procedures

Customer security is a key consideration for Swissone Group Ltd and we take our commitment to safeguarding our client best interests extremely seriously.

We have implemented a series of KYC (Know Your Client) procedures designed to secure the private information of our clients while keeping company in line with compliance best practices and policies for financial services companies. These are aimed at preventing any instances of identity theft, money laundering, fraud or terror activity.

We operate on a strict Zero Tolerance basis. Any fraudulent activity will be documented and will result in the immediate closure of any trading accounts related to such activity. Funds deposited in any such accounts will be forfeited.

These procedures secure your personal data and your financial transactions remain secure. Without completing our KYC procedures, your trading activity will be limited, and you will not be able to withdraw funds from your account.

Opening and funding a trading account with us will require the following documents to be submitted:

1. Proof of Identity document (colored photo or scan), following can be submitted:

• Passport
• National Identity card

Proof of Identity document must clearly contain following:

• Full name
• Date of birth
• Date of issue and expiration
• Clear photo

The minimum validity period of an identity document must be 6 months before the expiration date.

2. Second identity document, (colored photo or scan), following can be submitted:
• Driving license
• Insurance ID
• Certificate of live birth/marriage/divorce
• Diploma
• Military ID

3. Colored photo of a document that confirms your address and is not older than 90 days from the date of issue. The photo must show your full address of residence, first and last names, date of issue and official stamp or barcode. You may submit your:
• Utility bill
• bank statement
• check
• certificate of residency
• penalty notice
• legal agreement

4. Colored photos of both sides of the signed card/s you used to deposit. For your security, please cover the CVV number and the seventh to twelfth digits of your card/s number/s, leaving the first six and last four digits visible on both sides of your card/s. The card holder’s name/s and expiry date/s must be visible

Submit the required documents in PDF / JPEG / JPG / PNG image formats to the compliance department [email protected]

Submit your compliance as soon as possible after activation of your trading account. Please note that your missing compliance may result limitations on your trading account.

Consider that with missing compliance any withdrawal requests from your trading account will not be processed.

Monitoring of withdrawal requests

Company’s withdrawal policy is set as follows:
– The Customer has a right to withdraw funds at any time. Company’s bonus, if applicable, can be withdrawn
only upon meeting certain conditions, as defined by the promotion campaign that has resulted in
granting the bonus to the Customer.
– The Customer has to provide the Company with the signed withdrawal application form.
– The requested amount must be withdrawn to the same account that was a source of funds subject to
the withdrawal request. Examples: if the Customer used a bank wire transfer – the withdrawal will be
made via a wire transfer to the same account, if it was charged from a credit card – the withdrawal
will be credited to the same credit card and so on.
The appropriate compliance procedure for withdrawals is set below.
Compliance procedures applicable in cases of withdrawals by the Customers

Step Transaction/function Responsible staff Result
Compliance procedures applicable in cases of withdrawals by the Customers
1. Customer provides the
Company with a signed
withdrawal form.
Staff responsible for
Retention for the
Customers.
Review the withdrawal from
and proceed to Step 2.
2. Identification of the Customer
(ID, telephone number, and
other details).
Confirming that the
Customer’s account has
sufficient funds for
withdrawal and, to the
extent bonus funds are
involved, that the Customer
met all conditions, as
defined by the promotion
campaign that has resulted
in granting the bonus to the
Customer.
Staff responsible for
Retention for the
Customers
If identification and
confirmation are successful,
submit the withdrawal form
to the Compliance
department.
If not – inform the customer.
3. Identification of the Customer,
review of Customer’s recent
transactions and determining
the appropriate method of
withdrawal.
Compliance
department.
CEO (if applicable)
The Board of directors
(if applicable).
If the review is successful –
submit the withdrawal form
to the Financial Department
for withdrawal execution.
In case any problem occurs,
the Compliance department
may return the application to
the staff responsible for
retention for the Customers
for additional information. In
high-risks situations the
Compliance department may
report to the CEO of the
Company. In such cases the
CEO may take a final decision
upon the withdrawal or, if the
situation is extraordinary,
report to the Board of
directors.

To the extent possible, all suspicious transactions should be reported to the Compliance department
before they are executed. Full details of all suspicious transactions, whether executed or not, should be
reported to the Compliance department.
A suspicious transaction, noted prior to its execution, should be executed only with a pre-approval of the
Compliance department.
The Compliance department shall have reasonable access to all necessary information/documents that
might be needed to execute its responsibilities in an effective and due diligent manner.

The Compliance department is responsible for informing the CEO about any significant suspicious activity
noted. The CEO should escalate any extraordinary suspicious activity to the Board of Directors of the
Company.
The Board of Directors takes a decision to:
– escalate any extraordinary suspicious activity to the Financial Intelligence Unit (FIU) by Suspicious Activity
Report (SAR) or Suspicious Transaction Report (STR). SARs and STRs include detailed information
about transactions that are or appear to be suspicious. The goal of SARs and STRs filings is to help the
government identify individuals, groups and organizations involved in fraud, terrorist financing,
money laundering, and other crimes. The purpose of a suspicious activity report is to report known or
suspected violations of law or suspicious activity observed;
– take reasonable measures to ascertain the purpose of the transaction, the origin and ultimate
destination of the funds involved and the identity and address, of any ultimate beneficiary.

4. Training of personnel

The Company maintains an onboarding and ongoing employee-training program to ensure that relevant
staff is adequately trained in KYC procedures. The timing and content of training varies based on the target
audience. Training requirements should have a different focus for new staff, staff dealing with new
customers or customer retention.
New staff is educated about the basics of AML / CFT and KYC procedures and the importance of
implementation of all relevant compliance policies. These basic compliance requirements are presented
to them during two-week onboarding training that every new staff member has to attend. Staff members
who deal directly with the customers are trained to verify the identity of new customers, to exercise due
diligence in handling accounts of existing customers on an ongoing basis and to detect patterns of
suspicious activity.
Regular refresher training is provided to ensure that employees are reminded of their responsibilities and
are kept informed of new developments.
It is crucial that all relevant staff fully understand the need for and implement KYC policies consistently. A
culture within services that promotes such understanding is the key to a successful implementation.

Penalties Due to Non Compliance

The employees are expected to comply with compliance policies and procedures outlined in this manual.
Failure to comply might have serious implications including disciplinary action and in some cases even
individual criminal penalties.

Communication with Employees

Open channels of communication are set between the Compliance department of the Company and all
other employees of the Companies. Periodic updates about AML / CFT and KYC issues are provided to the
staff of the Company. The Company has established an onboarding and ongoing employee-training
program to ensure that the staff is adequately trained in compliance procedures. Training objectives have
different focuses on frontline staff, compliance staff and retention staff to ensure that all those concerned
fully understand the rationale behind the procedures and policies and implement them consistently.

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