AMLTF Policy

Terminology

1. Responsibilities of the Company

2. Responsibilities of the Client

3. Client Authentication

4. Deposit and Withdrawal Funds

5. Due Diligence Policy

WALDORA FINTECH PRODUCTS INC. presents to your attention this AMLTF Policy (hereinafter referred to as the “Policy”). Please note that the Client automatically accepts the terms of this Policy after accepting the Basic Offer, which is available on the Company's official website: https://waldoragroup.com. This document sets forth key standards and approaches to organizing the Company's internal control in the area of combating laundering of money obtained illegally, as well as financing of terrorism (hereinafter referred to as AMLTF). The Client agrees to fully comply with this Policy and, if it is not observed, bears the responsibility stipulated by law and this document, including liability for unlawful actions of third parties.

Terminology

  • Account is a trading, registered or other account, including deposit accounts, opened in the name and belong to the Client in accordance with legislation of the country of residence and other rules.
  • Money laundering is the legalization of money and assets obtained as a result of illegal activities.
  • Anti-money laundering procedures are legal, informational, and technical procedures developed by the governments of respective states and aimed at identifying and preventing operations with money or other property obtained through illegal activities or aimed at financing terrorist activities.
  • The placement of funds or other property implies their actual placement in financial institutions; transformation of illegal income into other assets and financial instruments; purchase of expensive goods for cash and subsequent resale. Most often, foreign banks that do not have effective regulatory documents and internal policies in the field of AMLTF are used to legalize illegal income, which in the future will be transferred to regulated areas in the form of already “legitimate” assets.
  • Stratification involves actions aimed at separating some of the proceeds from their original source by various financial transactions and hiding the original source of income.
  • Integration of cash and other assets is the placement of previously laundered cash and other assets in the economy for their subsequent legalization and use for purchases or illegal actions.

1. Responsibilities of the Company

1.1. Comply with the requirements of state authorities of the Client’s residence state, as well as international standards related to combating illegal trade and AMLTF.

1.2.Company undertakes to comply with legislation of the country whose jurisdiction it operates under, as well as international standards for combating illegal trade and AMLTF.

1.3. Keep confidential information relating to corporate standards and Company policies in the field of AMLTF, unless otherwise provided by legislation.

1.4. Collaborate with government agencies in the field of collection of information, implementation of preliminary investigative actions, court proceedings and the use of coercive measures regarding any facts that indicate a violation of AMLTF requirements.

1.5. Not to inform Clients and other persons on the details of AMLFT procedures, as this prevents the correct implementation of AMLFT measures.

1.6. The Company carries out regular checks of persons, including own employees who work under civil contracts. Any suspicious information about such persons is provided to the administrative bodies of the Company for making a decision, depending on the circumstances, to prevent or initiate an investigation regarding this person and, if necessary, impose sanctions. If employees of the Company have accounts with the Company, then they fall under the relevant legislation, the provisions of this Policy and other corporate policies of the Company.

2. Responsibilities of the Client

2.1. Comply with the requirements of legislation of the Client’s residence state, as well as international standards related to combating against illegal trade and AMLTF.

2.2. Guarantee and, if necessary, confirm the legitimacy of the origin of money and other assets, confirm ownership of property or rights to use or own property.

2.3. Not to engage directly or indirectly in illegal operations using information and telecommunication technologies, as well as audiovisual and other programs.

2.4. Fulfill obligations to the Company in accordance with legislation of the country of residence, international conventions and other international standards, this Policy and other corporate rules of the Company.

2.5. At the request of the Company, submit documents that certify the status of the Client for identification:

2.5.1. for individuals: documents valid at the time of submitting contain identification information, as well as a sample personal signature.

2.5.2. for legal entities: documents valid at the time of submitting contain information identifying the sole executive body of the Client, certify the authority of this body, constituent documents, as well as documents certifying the status of legal entities, the list of participants or the register of shareholders or another registry containing information about the beneficial owners of the legal entity, a sample of the seal (if any).

2.6. Present the above documents in originals or copies with a certified translation into the language of the country of residence if the identifying documents of the Client are executed in whole or in part in a foreign language.

2.7. Submit legalized documents if they are issued by state authorities of foreign countries.

2.8. Clients are duly informed and understand that the regulation of legal relations between them and the Company can be carried out by the laws and regulations of the countries of residence that are parties to international treaties and conventions in the field of AMLTF.

3. Client Authentication

3.1. In addition to the Client identification procedures provided for by this Policy, the Company carries out:

  • comprehensive verification of clients who are legal entities, including anti-corruption examination of constituent documents;
  • customer survey (by sending profiles);
  • oral survey with recording information in the Client's profile;
  • identification of clients who act on behalf of other clients as a representative;
  • other activities the Company considers appropriate to achieve the objectives of this Policy.

3.2. In order to identify suspicious activities of the Client, the Company has the right to monitor his activities and compliance with AMLTF standards.

3.3. If the Client refuses to provide the information necessary according to the requirements of this Policy, or purposely distorts such information, the Company reserves the right not to provide services and enter into agreements with such a Client, to cancel any existing agreements and contracts with such a Client, as well as stop providing any services. In this case, such a client receives a conditional status of "increased risk".

3.4. Company has the right to track information about the Client’s transactions in order to identify transactions considered unusual and suspicious.

3.5. Company maintains control over the activities of the Client and compliance with AMLTF standards if the Client or his representative:

  • provides false or misleading identification information;
  • has a bad reputation;
  • is overly concerned about the Company's compliance with state reporting standards, as well as AMLTF Policy, does not want or refuses to inform the Company about his own activities, provides identification or business documents that are suspicious;
  • does not pay attention to investment and other financial risks;
  • cannot describe the planned or existing business and its scope;
  • requires privileges to other clients regarding implementation of the requirements of this Policy;
  • has accounts in countries that do not comply with the requirements of FATF group (Group for the development of measures to combat money laundering);
  • carries out an unjustifiably large number of operations between accounts interconnected without any specific commercial task.

*The specified list of events is not exhaustive

3.6. If any of the above events is detected, the Company must collect, process and analyze additional internal or external information, contact the law enforcement authorities of the respective states and freeze the account, depending on circumstances.

4. Deposit and Withdrawal Funds

4.1. If the Client deposits money into the account, then he acts as a payer. In this case, the name of the payer must necessarily coincide with the name of the Client. Third parties are not allowed to deposit money into the Client's account.

4.2. For bank transfers and online transfers, the deposit and withdrawal accounts must coincide.

4.3. When withdrawing funds, the name of the Client who withdraws money must coincide with the name of the Client acting as the owner of account which the money is withdrawn from.

5. Due Diligence Policy

5.1. Together with the Know Your Customer Policy, the Company carries out due diligence, checking the competitiveness and rating of Client among similar structures. Due diligence is used to prevent corruption that directly or indirectly affects the violation of AMLTF requirements. As a result of such a comprehensive audit, the Company decides on the presence of legal risks, the financial reliability of the Client and his willingness to conduct investment activities.

5.1.1. For the purposes of this Policy, the term “corruption” includes: abuse of power, bribery, abuse of authority, bribery or other abuse by the Client or his representatives / beneficial owners of their powers regarding the legitimate interests of society and the country to obtain benefits, for personal interests or in the interests of others, as well as the unlawful provision of such benefits.

5.1.2. After filling out the Client’s application, the Company has the right to:

  • verify the accuracy and reliability of the financial and other corporate information of the Customer;
  • make requests for confirmation of estimates made in the business plan of the Client;
  • assess the appropriateness of the Client’s strategy;
  • check documents for compliance with legislation of the country of residence and the internal policies of the Company;
  • verify the correctness of the Client’s reporting;
  • check if necessary if the Client has permits;
  • establish the amount of internal as well as external debt of the Customer, if any;
  • make sure that the Client has the authority and competence to conduct relevant activities.

5.2. The Company reserves the right to use other procedures and comprehensive verification tools regarding its own Clients for professional examination of such information about the Client:

  • history and stages of development of the Client;
  • key tasks of the Client’s work, methods for their implementation;
  • Client positioning in the market, its prospects;
  • main strategic objectives and performance indicators of the Client;
  • compliance of the Customer's tasks with the SMART principle;
  • compliance of the used strategy with the existing position of the Client;
  • identification of persons involved in the formation of strategies;
  • key areas of the Client's investment policy;
  • list of controls used in the activities of the Client;
  • compliance with the formal and real structure of the Client;
  • information on optimizing control and management policies to minimize administrative costs and accelerate response to existing administrative actions;
  • key procedures and processes of the Client's business activities;
  • organization of key economic processes;
  • a list of laws and internal policies governing the economic and financial processes of the Client;
  • compliance of the above processes with legislation and internal policies of the Client;
  • Pros and cons of economic and financial processes.

Most often, the following economic and financial processes are subject to analysis:

  • marketing;
  • sales organization;
  • production;
  • supply and management;
  • development / design;
  • procurement and supply;
  • financial and economic management;
  • investment and investment management;
  • quality control.

Based on the analysis of these areas, the Company is able to make conclusions on:

  • compliance of the Client’s management with legislation of the country of residence or internal policies, as well as with the Client’s procedures;
  • compliance of the Client management practices with similar management practices in a similar field;
  • main economic and financial processes with consideration of their possible demerits;
  • advice and action plan of the Client on improving and optimizing management processes.