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AML policy

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Identification Policy and AML

1 Policies for risk assessment of AML in the Company in accordance with Section 21 and Act No. 253/2008 Coll., On Certain Measures Against Legalization of Proceeds from Crime and Financing of Terrorism (CZ), currently in force (AML4 Act)

The Company implements the principles for assessing the risks associated with the provision of payment services, categorizing clients according to their degree of risk to the Company. This categorization includes the risk definition of individual products and services provided, the riskiness of individual groups of clients with respect to risk factors.

Responsible persons for the risk assessment of AML in the Company are:

Name and surname Work position Contacts of responsible person
Bohdan Taranenko Executive and Compliance Manager
Yulia Salnikova Compliance Manager (Clients‘ Identification)

2 When identifying a natural person - a client or a representative of a client acting on the basis of power of attorney, the following information is required:

* if any of the information is not listed in the document and if it does not appear from the available records, the client will be required to present the information with a supporting document (for example, another identity card or another credible document where is not a condition of being issued by a state authority, e.g. birth certificate, employment card, residence certificate, energy invoice, etc.).

After reviewing the data stated above, the compliance of the client appearance with the photo in his/her identity card will be checked. This compliance is verified by comparing the actual physical appearance of the person with his / her picture in the identity card by the Company's liable entity. If a person's identity is questioned because the current appearance seems to be different with comparation of the appearance in the identity card´s photo, the person proceeding the identification process will refuse to identify the person according to this document and will request another identity card for identification.

3 When identifying a legal entity - a client and a responsible representative of the client or a person acting on the basis of a power of attorney, the following information is required:

In the case of the identification of a legal entity, the responsible person in the Company shall ensure that the actual owner of the Client is identified. If the Company's responsible person discovers that there is an opaque ownership structure or any other attempt by the Client to hide or conceal the person of the beneficial owner, or by reason of his / her actions, he / she invokes reasonable suspicion of the actual owner, the responsible person of the Company shall refuse to register the Client in the payment system and mark that event incident, including reporting to the FAÚ.