The Policy of Preventing the Legalization of Proceeds from Crime, the Financing of Terrorism and the “Know Your Customer” Policy
The Policy to Prevent the Legalization of Proceeds from Crime, the Financing of Terrorism and the "Know Your Customer" Policy (hereinafter referred to as the "Policy") is designed to prevent and reduce the possible risks of Findex24 being involved in any illegal activity.
In order to comply with international and local regulations, Findex24 implements effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to respond in case of any form of suspicious activity on the part of its Users.
"Money Laundering (legalization of proceeds from crime)" should be understood as "the transfer or transfer of property, knowing that such property is obtained from criminal activity or from participation in such activities, in order to conceal or disguise the illegal origin of property or to assist any person involved in the commission of such activities in order to evade the legal consequences of his actions."
"Financing of Terrorism" should be understood as "the deliberate provision or collection by any means, directly or indirectly, of funds with the intention of using these funds or on condition that they will be used to commit terrorist acts."
All companies must comply with the Regulations on the Prevention of the Legalization of Proceeds from Crime, the Financing of Terrorism and the Transfer of Funds (Information about the Payer) of 2017 and be aware of the guidelines established by the Joint Steering Group for the Control of Money Laundering, which provide guidelines in the UK on how companies should conduct a comprehensive legal verification of their clients, as well as recommendations of the Financial Action Task Force on Money Laundering, an intergovernmental body whose main purpose is to develop and promote national and international policies to combat the legalization of proceeds from crime and the financing of terrorism.
Other legislative acts concerning the fight against the legalization of proceeds from crime and the financing of terrorism are the following acts:
- 5th Anti-Money Laundering Directive ((EU) 2018/843);
- Proceeds of Crime Act of 2002;
- Terrorism Laws of 2000 and 2001;
- The Anti-Terrorism Act of 2008;
- Treasury Sanctions Notices;
- Handbook of the Financial Conduct Authority.
The policy includes the following sections:
- Verification Procedures;
- The role of the Head of the Corporate Regulation and Control Department (hereinafter referred to as the "Responsible Official");
- Transaction Monitoring;
- Risk Assessment;
- Country Of Residence.
To help combat the financing of terrorism and money laundering, the Law requires that all financial institutions receive, verify and register information identifying each individual or legal entity opening an Account.
By law, we are required to ask you to provide your name, address, date of birth and other information about you, your organization or persons associated with your organization that will allow us to identify you before we approve your Account.
We may also ask you to provide certain identification documents, such as your driver's license or passport or the founding document of your organization, and we may obtain your credit history and other consumer reports, in order to verify your identity and determine whether you meet the criteria for opening an Account with us.
If you do not provide the requested information and documentation, we will not be able to open an Account for you.
By applying to open an Account on Findex24, you agree to provide the information and documentation requested by Findex24 and agree to Findex24 receiving your credit history and other consumer reports about you for the purposes described above.
The Findex24 customer due diligence procedure requires Users to provide Findex24 with reliable, independent source documents to identify them and to confirm their residential address. Such documents may include, for example, a national ID card, an international passport, a bank statement, a utility bill. For these purposes, Findex24 reserves the right to collect User identification information for the purposes of compliance with the Policy.
Findex24 will take steps to verify the authenticity of documents and information provided by Users. Findex24 will also verify identification information using secondary sources, and Findex24 reserves the right to continue investigating cases where Users are not satisfied with the documentation provided.
Findex24 reserves the right to monitor User data on an ongoing basis, especially when his identification information has been changed or his activity has seemed suspicious (unusual for a particular User). In addition, Findex24 reserves the right to request current documents from Users, even if they have been authenticated in the past.
Findex24 and the relevant rules. The User agrees that if any information provided in the application for opening an Account changes, ceases to be true or becomes substantially misleading (including, but not limited to, the ownership of the Account) - in this case, the User will notify Findex24 of such changes.
After confirming the identity of the User, Findex24 may refuse to provide Services to the User in a situation where it is suspected that the Findex24 Services are used to conduct illegal activities.
Findex24 has a regulatory requirement to verify the source of Fiat Money and/or Cryptocurrencies in order to know that the sources of funds that Users use for trading are legitimate. Findex24 will need confirmation of the source of funds: it can be a bank statement for fiat funds or a video showing the details of a wallet transaction for cryptocurrencies.
Users who intend to use payment cards for the purpose of consuming services must pass card verification in accordance with the instructions available on the Findex24 website.
Findex24 uses independent third-party companies for the following purposes:
- checking Users against lists of politically exposed persons (PEP) and sanctions lists, as well as checking for unwanted media.
- evaluation of the User's Cryptocurrency wallets for investigation and compliance with AML requirements.
- Findex24 reserves the right to close or reject Accounts based on information received by third-party companies, including Users connected to "high risk" wallets.
The Responsible Official is a person who has been duly authorized by Findex24, and whose responsibility is to ensure the effective implementation and enforcement of the Policy. The responsibility of such a Responsible Official is to monitor all aspects of Findex24's activities to counteract the legalization of proceeds from crime and the financing of terrorism, including, but not limited to, the following methods:
- collection of user identification information;
- create and update internal policies and procedures to complete, review, submit and store all reports and records required by applicable laws and regulations;
- monitoring of transactions and investigation of any significant deviations from normal activities;
- implementation of a records management system for the appropriate storage and retrieval of documents, files, forms and logs, regular updating of the risk assessment system, provision of information to law enforcement agencies required in accordance with applicable laws and regulations.
The Responsible Official is the contact person of Findex24 when interacting with law enforcement agencies in order to prevent money laundering, terrorist financing and other illegal activities.
Findex24 users must go through the Findex24 identity verification process (determining who you are) before trading. After the verification is completed, the User consents to transaction monitoring, and Findex24 analyzes the User's transaction patterns (what they do).
Findex24 relies on data analysis as tools for risk assessment and detection of suspicious activity. These tools perform a variety of regulatory compliance tasks, including data collection, filtering, record keeping, investigation management, and reporting.
- monitor all transactions. Findex24 reserves the right to ensure the transmission of messages about the suspicious nature of transactions to the appropriate law enforcement agencies through a Responsible Official;
- request any additional information and documents from the User in case of suspicious transactions;
- suspend or terminate a User's account if Findex24 has a reasonable suspicion that such a User is involved in illegal activities.
At the same time, the above list is not exhaustive, and the Responsible Official will monitor User transactions on a daily basis to determine whether such transactions should be reported and treated as suspicious or which should be treated as bona fide.
To fulfill its obligations to combat money laundering (AML) and counter terrorist financing (CTF), Findex24 conducts an annual AML risk assessment. The aim of the AML risk assessment is to prevent criminals from using Findex24 for money laundering by highlighting the risks and evaluating the controls established by Findex24. A risk-based approach is used to identify Users and track how they use our Services.
The Responsible Official is responsible for managing the risks of financial crimes and making improvements to the risk management of financial crimes by identifying the general and specific money laundering risks faced by Findex24, determining how these risks are mitigated by Findex24 AML controls, and determining the residual risk that remains for Findex24.
Findex24 defines its risk criteria for AML/CTF in this Policy. To reduce this risk, Findex24 does not accept clients who reside in countries that are considered above certain Findex24 risk criteria.
Sources used for categorization:
- Transparency International;
- Know Your Country;
- List of FATF jurisdictions with a high level of risk;
- List of high-risk EU jurisdictions;
- Countries where digital assets are prohibited or there are restrictions on trade;
- Countries where digital assets are not prohibited;
- Countries subject to the UN Security Council sanctions regime.
It should be clear that Findex24's policy is that all customers residing in the countries listed below are prohibited from serving Findex24 and cannot be accepted as customers. Any customers who try to open an Account will be refused, and any funds will be returned to the source.
Full list of prohibited jurisdictions
- Bahamian Islands
- Burma (Myanmar)
- Central African Republic
- Ivory Coast
- Democratic People's Republic of Korea (DPRK)
- Equatorial Guinea
- Lao People's Democratic Republic
- North Macedonia
- Russian Federation
- Saudi Arabia
- South Sudan
Findex24 also does not accept clients from disputed territories, as they do not provide generally recognized official documents, including:
- Donetsk People's Republic (DPR) / Luhansk People's Republic (LPR)
- Pridnestrovian Moldavian Republic
- Republic of Somaliland
- Turkish Republic of Northern Cyprus
- Republic of China (Taiwan)
- Republic of Kosovo
- Sahrawi Arab Democratic Republic