Anti-Money Laundering Policy

Introduction

Coinance OÜ wishes to put in place the following anti-money laundering policy in order to prevent any of our services being used (or potentially used) for any money laundering activity, as well as any of our staff being exposed to money laundering.

Scope of the Policy

The broad definition of money laundering means that potentially anyone could commit a money laundering offence, this includes all employees of the Company, all temporary staff and contractors.

Our policy is to enable the Company to meet its legal and regulatory requirements in a way which is proportionate to the nature of the business, by taking reasonable steps to minimise the likelihood of money laundering occurring.

All employees must be familiar with their legal responsibilities, and failure to comply with this Policy may lead to disciplinary action.


What is Money Laundering?

The Proceeds of Crime Act 2002 (POCA) consolidated, updated and reformed criminal law with regard to money laundering.

Money laundering can be defined as the process to move illegally acquired cash through financial systems so that it appears to be from a legitimate source. Money laundering offences include: concealing, disguising, converting, transferring criminal property or removing it, entering into or becoming concerned in an arrangement which you know or suspect facilitates the acquisition, retention, use or control of criminal property by or on behalf of another person; and acquiring, using or possessing criminal property.

There are also several secondary offences, failure to disclose knowledge or suspicion of money laundering to the Money Laundering Reporting Officer (MLRO); failure by the MLRO to disclose knowledge or suspicion of money laundering to the National Crime Agency; and ‘tipping off’ whereby somebody informs a person or persons who are, or who are suspected of being involved in money laundering, in such a way as to reduce the likelihood of their being investigated or prejudicing an investigation.

Any member of staff could potentially be caught by the money laundering provisions, if they suspect money laundering and either become involved with it in some way, and/or do nothing about it. This Policy sets out how any concerns should be raised.

Money Laundering Reporting Officer (MLRO)

Coinance will appoint a MLRO to receive disclosures about money laundering activity and be responsible for anti-money laundering activity within the Company. The officer nominated to do this is Alexander Razvadovskis.

The MLRO will ensure that appropriate training and awareness is provided to new and existing employees and that this is reviewed and updated as required. The MLRO will ensure that appropriate anti-money laundering systems and processes are incorporated by the Company.

The main activities of the MLRO comprise, but are not limited to, the following:

• Oversight of all aspects of the company’s AML and CTF activities;
• Focal point for all activities within the company relating to AML and CTF;
• Provision of AML training to all staff;
• Receiving all internal suspicious activity reports and, where deemed applicable, reporting to relevant authorities on the same;
• Be the focal point for law enforcement and other regulatory bodies;
• Establishing the basis on which a risk-based approach to the prevention of money laundering and terrorist financing is put into practice;
• Supporting and co-ordinating senior management focus on managing the money laundering/terrorist financing risk in individual business areas;
• Advising the business on new products / processes from an AML perspective;

The MLRO is also required to produce reports for Board meetings including, but not limited to, the following items:

• Confirmation that adequate customer due diligence information is being collected and that ongoing monitoring is taking place;
• Summary data relating to complex or unusual transactions;
• Number of internal consents / Suspicious Activity Reports (SARs) received from staff members;
• Number of SARs sent externally;
• Information on status of staff training within the company;
• Confirmation that all business records have been properly stored and are retained according to regulatory requirements;
• Changes in the law/operating environment which do or might impact the business;
• Changes in the risk matrix affecting the business;
• Contacts with the regulator;

Suspicions of Money Laundering

All Coinance employees, staff and contractors, must immediately report any suspicious activity to the MLRO in the prescribed form as set out in this policy document.

Once the matter has been reported to the MLRO, the employees must follow the directions given to them and must NOT make any further enquiry into the matter.

Coinance employees must NOT voice any suspicions to the client(s) whom they suspect of money laundering, as this may result in the commission of the offence of “tipping off”. They must NOT discuss the matter with others or note on the file that a report has been made to the MLRO in case this results in the suspect becoming aware of the situation.

Consideration of the Disclosure by the MLRO

Once the MLRO has received the report, it must be evaluated in a timely manner in order to determine whether:

• There is actual or suspected money laundering taking place;
• There are reasonable grounds to know or suspect that this is the case;
• Whether the MLRO needs to lodge a Suspicious Activity Report (SAR) with the National Crime Agency (the NCA).

Where the MLRO concludes that there are no reasonable grounds to suspect money laundering then consent will be given for any on-going or imminent transaction(s) to proceed.

Where consent is required from the NCA for a transaction to proceed, then the transaction(s) in question must not be undertaken or completed until the NCA has given specific consent, or there is deemed consent through the expiration of the relevant time limits without objection from the NCA.

All disclosure reports referred to the MLRO and reports made to the NCA will be retained by the MLRO in a confidential file kept for that purpose, for a minimum of 5 years.

The MLRO must also consider whether additional notifications and reports to other relevant enforcement agencies should be made.

Customer Identification and Due Diligence

Due diligence is performed on all customers who must provide basic information including name, address, registration details (corporate bodies).

During the process of client registration in Coinance platform, the following details must be provided:

Individual Clients

• Full name of the client;
• Date of birth;
• Country of origin and residence;
• Mobile phone number;
• Email address.

Individual clients must furthermore provide high resolution, scanned copy or photo of the passport or national ID, with the name, date and place of birth, passport number, issue and expiry dates, issuing country and signature of the customer

Corporate Clients

• Full business name;
• Registration number and date;
• Country of incorporation / registration;
• Company registered address;
• Mobile phone number;
• Email address.

Corporate clients must furthermore provide high-resolution copies of documents such as certificate of registration, and, where applicable, the name change certificate, certificate of good standing, articles of incorporation, the government issued business license (if applicable), etc.

With instructions from new customers or customers not known well to the Company, customers in known high risk industries and/or jurisdictions, transactions that are unusual for the customer or other unusual requests, highly complex transactions or payment arrangements, the Company may wish to seek additional evidence of identity. This may include:

• Obtaining information relating to the source of funds or the client's wealth (this will be done via email or over the phone);
• Requesting more information from the customer or from the company's own research and third-party sources to clarify the client update information, getting any additional information to clarify the nature and purpose of customer transactions with the Company.
• Checking the organisations website to confirm the identity of personnel, its business address and any other details;
• Attending the customer at their business address;
• Evidence or the personal identity of the key contact officer (passport, photo, driving licence).

If satisfactory evidence of identity is not obtained at the outset then the business relationship or one off transaction(s) cannot proceed any further.

Record Keeping

Where “relevant business” is carried out, the customer identification evidence and details of the relevant transaction(s) for that customer must be retained for at least 5 years.

Coinance will principally retain the following records from an AML perspective:

• Records of customer screening (PEPs & Sanctions);
• Copies of, or references to, the evidence obtained of a customer’s identity for five years after the end of the customer relationship;
• Details of customer transactions for five years from the date of the relevant transaction;
• Records of all AML/CTF training delivered;
• Details of actions taken in respect of internal and external suspicion reports;
• Details of information considered by the MLRO or his nominee in respect of an internal report where no external report is made.