Anti-Money Laundering (AML) Policy

General information about the Company:

Comert Comertex spool. s.r.o maintains high standards of work in combating money laundering and actively discourages any action aimed at or facilitating the process of money laundering.

The jurisdiction in which the Company is registered has a well-developed legislation in the field of regulation of the Forex industry. The Company is annually checked for violations of the provisions of the law, as a result of which it receives documentary confirmation from the State Registrar that the Company exists and operates in full compliance with national laws. In addition, the Company annually receives an independent legal opinion from companies on the “TheLegal500” list, which serves as additional confirmation in favor of the legality of the Company’s actions and their consistency with national regulations.

In order to detect, prevent and alert about all transactions aimed at converting funds received as a result of illegal activities into another type of funds that are legality in nature, the Company has developed the following procedures:

 

Monitoring customer activity.

Customer activity is monitored in many different ways at all levels of customer interest and engagement. So, at the primary level, clients receive the “Lead” status – clients who are interested in the company’s services, have been on the company’s website for a long time, and so on. The information collected on such clients is reflected in the report, which is used by the company’s financial consultants for further work with clients and their qualitative assessment. Further, clients who have registered and completed the KYC / AML procedure receive the “NewClient” status. Such clients, depending on their potential, experience in the field of independent trading and other factors, are divided into “Silver”, “Gold” and “Platinum” – the activities of such clients in each separate subgroup are monitored by the Company’s employees for a number of critical indicators (in particular, the activity report replenishment of a new client – amount, quantity, average bill, currency, preferred payment method – information that allows you to assign an initial assessment of the client’s risk). Then, active clients are divided by market geography – quantitative indicators, methods of replenishment, preferred trading strategies, frequency of transactions, use of trading indicators and more. At the end of the client cycle, in the absence of client activity on trading accounts, clients included in a separate report are indirectly checked by financial consultants, who clarify the reason for the termination of trading activities.

 

Monitoring of payments for replenishment and withdrawal.

All client transactions for deposits and withdrawals from a personal trading account must meet the following requirements:

– In the case of a bank transfer or transfer from a bank card, the name specified when registering an account must match the name of the account / bank card holder. Any replenishment of the account using a bank card will be valid only after:
a) confirmation of the client’s identity (for this you need to upload a high-quality photo or scanned copy of the identity document in the Client’s personal account), and
b) verification of a bank card (for this you need to upload a photo of a bank card, on which the first 6 digits and the last 4 digits of the card must be clearly visible).
– In the case of replenishing the account in a way that cannot be used for withdrawal, the funds are withdrawn to the Client’s bank account, or in another way as agreed with the Company, with which it is possible to reliably establish the identity of the account holder.
– When replenishing an account in various ways, funds are withdrawn by the same methods in proportion to the amount of deposits.

 

Training of employees in the modern rules of AML procedures.

The employees of the financial department responsible for the operations of deposits and withdrawals of clients, as well as for the verification of the main identification documents, constantly study the market for updates to the AML policy, periodically conduct trainings on updating regulations in accordance with the FATF and Big4 bulletins. On a quarterly basis, employees are certified for the knowledge of the information necessary for effective work, in particular, regarding the CTF / AML / KYC procedures of the Company.

 

Timely response to “RedFlags” and other signs of suspicious customer behavior.

All non-trading financial transactions are checked for money laundering at all stages of the movement of funds in case of money laundering:

– Accommodation.
At this stage, the funds are converted into other financial instruments such as checks, bank accounts, money orders, or they can be used to purchase high-value goods that can be resold. They can also be invested in banks and non-banking institutions (for example, currency exchange offices). To avoid suspicion on the part of the company, a money launderer can make several investments instead of investing the entire amount at once. This form of placement is called “smerfing” or “spraying”.

– Splitting up.
Funds are transferred or transferred to other accounts and other financial instruments. This is done in order to hide the origin and prevent

b identification of the person who has carried out several financial transactions. The movement and reshaping of funds complicates the process of tracking money laundered.

– Integration.
Funds are returned to circulation as legally received for the purchase of goods and services.

The company has introduced a unique practice “Moratorium” – a ban on withdrawal of funds for 10 days if the client has raised funds, but did not trade in the financial markets. Also, operations to replenish funds are checked for the so-called “busting of cards” (using several cards through different payment agents offered by the Company, receiving a specific error code during payment, using cards issued by issuers located in different regions), using several cards in a short period of time. payment instruments (cards, e-wallets, bank transfers), refusal to verify any payment instrument, mismatch of the geography of key elements (citizenship, mobile phone operator, geolocation of IP addresses, BIN cards, etc.), fundamental refusal to conduct a telephone conversation, failure to provide a photo a client with an identification document in his hands upon request, the CID of the computer of one account coincides with another account in our system.

Thus, in order to prevent the use of the Company’s services by criminals for the purpose of money laundering, terrorist financing or other criminal activity, Comert Comertex spool. s.r.o undertakes:

– Request the relevant identity documents to identify the Client;

– Assess the risk of whether the Client is involved in money laundering or terrorist financing;

– Check whether the country of origin of the Client belongs to countries that, in accordance with the FATF, do not comply with the requirements for preventing money laundering and terrorist financing;

– Re-identify the Client if there are doubts about the correctness of the information obtained during the initial identification;

– Do not enter into business relationships with anonymous customers.

Risk assessment takes into account three categories of risk:

– place of residence or location of the person – country and geographic risks are taken into account *;

– parameters characterizing the person participating in the transaction – the client’s risk is taken into account;

– business activity of the person participating in the transaction – the risks associated with the product and services are taken into account;

* Countries that, according to the FATF, do not comply with the requirements for the prevention of money laundering and terrorist financing. You can find a list of these countries here.

 

After assessing these risks, each risk category is assessed on a three-point scale:

– Low risk

No risk factors in each category, customer transactions are transparent and do not deviate from normal transactions; a sane person who conducts business in the relevant field. Thus, there is no reason to suspect that risk factors in general could lead to a threat of money laundering or terrorist financing.

– Average level of risk

One or more risk factors in a category that are different from the normal operations of the person doing business in the relevant area, but the operations are still transparent. Thus, there is no reason to suspect that risk factors may generally give rise to the threat of money laundering or terrorist financing.

– High level of risk

One feature or more in a category that generally undermines the transparency of a person and their operations, making the person in question different from the person working in the relevant field. Therefore, there is a risk of money laundering or terrorist financing.

The company reserves the right to collect additional customer identification data for the purposes of the AML / KYC policy.

The data and documents used to identify the client by the Company will be collected, stored, shared and protected strictly in accordance with the provisions of the Law on Anti-Money Laundering (Laundering) of Proceeds from Crime and the Financing of Terrorism in accordance with the Company’s internal privacy policy and applicable guidelines .