Money laundering and the financing of terrorism are financial crimes with economic effects. To qualify as an illegal activity, it requires an underlying, primary, profit-making crime (such as corruption, drug trafficking, market manipulation, fraud, tax evasion), along with the intent to conceal the proceeds of the crime or to further the criminal enterprise. This is a process in which the identity of the proceeds of crime is so disguised, that it gives an impression of legitimate income.

The purpose of AML/KYC policy is, by increasing the trustworthiness and transparency of the business environment, to prevent the use of the financial system for money laundering and terrorist financing. We adhere to strict laws (EU regulation and UK law) rendering it illegal for our company to knowingly engage in or attempt to engage in any activities remotely related to money laundering. Our anti-money laundering policy is designed to increase protection and enhance customers security services, as well as to offer safe payment processes.

MONELIQ, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. It controls, when effectively implemented, mitigate the adverse effects of criminal economic activity, including adequate systems and controls in place to alleviate the risk of committing financial crime. The policy establishes requirements aimed at the identification and analysis of the customers’ activities to prevent the company's interaction with persons engaged in activities related to the legalization of proceeds from crime and the financing of terrorism.

This AML Policy sets out the minimum standards which must be complied with and includes:

• Appointing a Money Laundering Reporting Officer (MLRO) who has a sufficient level of seniority and independence, and who has responsibility for oversight of compliance with the relevant legislation, regulations, rules, and industry guidance.
• Establishing and maintaining a Risk-Based Approach (RBA) to the assessment and management of money laundering and terrorist financing risks faced by the company.
• Establishing and maintaining risk-based Customer Due Diligence (CDD), identification, verification, and Know Your Customer (KYC) procedures, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs).
• Establishing and maintaining risk-based systems and procedures for the monitoring of on-going customer activity.
• Establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate.
• Maintaining appropriate records for the minimum prescribed periods.
• Providing training for and raising awareness among all relevant employees.

The first safeguard against money laundering is KYC verification. To ensure compliance with standard AML regulations, we require you (the customers) to fill and submit the following information:

• a) Personal information, such as name, date of birth, address, contacts.
• b) The identity documents, such as passport or ID card.
• c) Proof of residence, such as utility bill, bank account statement and others official documents issued within the last 3 months clearly stating your name and address as registered with MONELIQ.
• d) Identification of legal entities involves the following information: name, legal form, registration address, registration number, name of the person acting on behalf of the person, contacts, business activity. Document confirming the authority of the person who performs actions on behalf of the legal entity. Such as an extract from the register, which contains the names of Directors, the Charter of the company, from which the powers of Directors are evident, and the power of attorney. The document should contain data on the powers and terms of authority.
• e) Please note that, pursuant to EU and UK legislation, we may need to request further documentation from our customers (such as card verification, and bank information).

MONELIQ will take steps to confirm the authenticity of the documents and information provided by the customer.

Please note: All required documents should be provided in good quality, all texts should be readable, and there should not be any modifications or edits of the document photos, as otherwise we would have to reject them and request new copies without modification or in better quality.

We will send a notice of decision to accept or to refuse the customer as our customers. The customers receive acceptance only after all requested documents are provided. This means that the company must gather information of the customers’ identity and verify their documents before applicants to our services will accept as the users. Documenting and maintaining these identification procedures enhance company’s ability to prevent money laundering activities.

MONELIQ sets different levels of regulatory protection to each customer within each risk profile.We have the right to impose additional due diligence requirements to accept the customer residing in certain countries, for politically exposed persons or for effective risks mitigation relating to money laundering and terrorist financing.

MONELIQ reserves the right to verify customers’ identity on an on-going basis, especially, when their identification information was changed, or activity seemed to be suspicious (unusual for the user). In addition, we reserve the right to request up-to-date documents from the customers, even though they have passed identity verification in the past.

Please note, if the customer exceed threshold, we will request from you to fill a questionnaire asking for information on “Source of Funds” and to attach of all relevant supporting documents to justify your statements. If this information is not satisfactory, the company reserves the rights to request additional information and documentation.

We apply enhanced due diligence measures and request all necessary information for risk mitigation and prevention of money laundering if a customer was identified as:

• a) a politically exposed person (“PEP”), or
• b) a PEP’s family member, or
• c) a person who is known to be the beneficial owner or to have joint beneficial ownership of a legal person or a legal arrangement, or any other close business relations.

MONELIQ screens applicants against recognised Sanctions and Politically Exposed Persons (PEPs) lists.Customer’s identification information will be collected, stored, shared, and protected strictly in accordance with our Privacy Policy and related regulations. The customers are known not only by verifying their identity, but, more importantly, by analysing their transaction activities. Therefore, MONELIQ relies on the data analysis as a risk-assessment and suspicion detection tool.

Our company tracks all suspicious operations of users. If we suspect illegal activities or money laundering, we have the right to delay, terminate or cancel such transaction at any stage In addition, we reserve the right to suspend or terminate any account or freeze funds in the account, if there is any reason to believe that the account was used for activities that was deemed illegal or fraudulent.

The company thoroughly monitors and analyses the activities of our customers and their accounts, and, in cases of suspicious transactions, requests to provide any additional information and documents.The monitoring functionality includes:

• a) Daily check
• b) Case and documents management

The Compliance Officer will monitor customers’ transactions on a day-to-day basis to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide. The company doesn’t open accounts for anonymous owners (i.e., without providing primary information before establishing business relationship). Each customer undertakes to carry out operations individually and independently. If the company has suspicions of passing control over the account management to the third party by the customer, we request full information about the third party and explanation from the customer about the reasons and causes for of this situation. In addition, the company reserves the right to:

• terminate account activities
• lock access to your personal account
• cancel transactions

MONELIQ doesn’t establish business relationships with individuals, companies and countries that are included in the sanctions lists by United Nations (UN), European Union (EU), UK Treasury and US Office of Foreign Assets Control (OFAC), Financial Action Task Force (FATF). MONELIQ is committed to conducting business in accordance with the highest ethical, professional, and legal standards. We will comply with applicable legislation. In line with applicable legislation, our company has a ‘zero tolerance’ policy towards fraud, corruption, collusion, money laundering, financing of terrorism and other criminal conduct. Our policies are compliant with the current applicable local (UK) and international (EU) legislation.

We perform KYC due diligence on all new customers and a due diligence on all transactions to detect possible compliance or integrity concern. Such due diligence is executed in accordance with the requirements of the money laundering and terrorist financing activities regulations, pursuant to the terms of KYC (see previous clauses). Such instruments as KYC, transactions monitoring and account activities analysis help us prevent or fast detect and investigate fraud and anti-money laundering by customers.