AML policy | Symlix.com

(Symlix marketplace AML POLICY)

(Last Updated February 8th, 2023)
  1. AML Overview
  2. Fort Exbit UAB Anti Money Laundering Policy
  3. Our AML/CFT Requests and Compliance
  4. Customers Who Refuse To Provide Information for AML/CFT Request
  5. Customer Identification Program
  6. Required Customer Information
  7. Know Your Customer KYC
  8. Verifying Customers Information
  9. Customers Who Refuse to Provide Information
  10. Lack of Verification
  11. Conducting Ongoing Monitoring to Identify and Report Suspicious Transactions
  12. Recordkeeping
  13. Monitoring Accounts for Suspicious Activity
  14. Contact Us

1.AML Overview

Anti-Money Laundering (AML) is a critical regulatory process, often lumped in with the KYC process. AML assures that the individual you are transacting with is permitted to do so. Along the same line, AML checks verify that an individual is not on any known bad actor list. These lists are constantly updated and monitored by Fort Exbit UAB.

2.Fort Exbit UAB Anti Money Laundering Policy

Fort Exbit UAB AML Policy prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Money Laundering and Terrorist Financing Prevention Act 2017 and United Kingdomn Financial Supervision and Resolution Authority. Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler's checks, or deposited into accounts at financial institutions. At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable United Kingdomn Financial Supervision and Resolution Authority regulations and AML/CFT rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

Pursuant to the AML and its implementing regulations, financial institutions are required to make certain searches of their records upon receiving an information request from Money Laundering and Terrorist Financing Prevention Act 2017. Describe Fort Exbit UAB’s procedures for Money Laundering and Terrorist Financing Prevention Act 2017 requests for information on money laundering or terrorist activity. In order for a firm to obtain information requests from Money Laundering and Terrorist Financing Prevention Act 2017, the firm must first designate an AML Contact Person in Fort Exbit UAB. You should be aware that if you want to change the person who receives Money Laundering and Terrorist Financing Prevention Act 2017 requests, you must change the AML contact information in Fort Exbit UAB. When you are faced with a change in personnel who will receive this information, you should be aware that Money Laundering and Terrorist Financing Prevention Act 2017 receives a data feed of this revised information from Fort Exbit UAB every other week and that it may take several weeks for a firm’s new AML contact person to receive information from Money Laundering and Terrorist Financing Prevention Act 2017. Therefore, it is advisable for a firm that is aware that a person who had been receiving Money Laundering and Terrorist Financing Prevention Act 2017 requests is leaving the firm to change the information on Fort Exbit UAB as soon as practical to ensure continuity of receiving (AML/CFT) information.

3.Our AML/CFT Requests and Compliance

By using the Fort Exbit UAB Services and app you agree that Fort Exbit UAB will respond to every Financial Crimes Enforcement Network (Money Laundering and Terrorist Financing Prevention Act 2017) request concerning accounts and transactions occurred during the use of our service or app by immediately searching our records to determine whether we maintain or have maintained any account for, or have engaged in any transaction with, each individual, entity or organization in question.

We understand that we have 14 days (unless otherwise specified by Money Laundering and Terrorist Financing Prevention Act office from the transmission date of the request to respond to AML/CFT Request. We will designate through the AML/CFT Contact System (Fort Exbit UAB) one or more persons to be the point of contact (POC) for AML/CFTs and will promptly update the POC information following any change in such information. Unless otherwise stated in the AML/CFT or specified by Money Laundering and Terrorist Financing Prevention Act 2017, we are required to search those documents outlined in Money Laundering and Terrorist Financing Prevention Act 2017’s FAQ. If we find a match, Fort Exbit UAB will report it to Money Laundering and Terrorist Financing Prevention Act 2017 via the Money Laundering and Terrorist Financing Prevention Act 2017’s Web-based Secure Information Sharing System within 14 days or within the time requested by Money Laundering and Terrorist Financing Prevention Act 2017 in the request. If the search parameters differ from those mentioned above (for example, if Money Laundering and Terrorist Financing Prevention Act 2017 limits the search to a geographic location), Fort Exbit UAB will structure our search accordingly.

If Fort Exbit UAB searches our records and does not find a matching account or transaction, then Fort Exbit UAB will not reply to the AML/CFT. We will maintain documentation that we have performed the required search by [add the details on how Fort Exbit UAB will document its searches here. For example, printing a search self-verification document from Money Laundering and Terrorist Financing Prevention Act 2017’s Secure Information Sharing System confirming that Fort Exbit UAB has searched the subject information against your records OR maintaining a log showing the date of the request, the number of accounts searched, the name of the individual conducting the search and a notation of whether or not a match was found].

Fort Exbit UAB will not disclose the fact that Money Laundering and Terrorist Financing Prevention Act 2017 has requested or obtained information from us, except to the extent necessary to comply with the information request. Fort Exbit UAB will review, maintain and implement procedures to protect the security and confidentiality of requests from Money Laundering and Terrorist Financing Prevention Act 2017 similar to those procedures established to satisfy the requirements of AML/CFT with regard to the protection of customers’ nonpublic information. We will direct any questions we have about the AML/CFT to the requesting federal law enforcement agency as designated in the request. Unless otherwise stated in the AML/CFT, we will not be required to treat the information request as continuing in nature, and we will not be required to treat the periodic AML/CFTs as a government provided list of suspected terrorists for purposes of the customer identification and verification requirements.

4.Customers Who Refuse To Provide Information for AML/CFT Request

Fort Exbit UAB: If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, Fort Exbit UAB will not open a new account and, after considering the risks involved, consider closing any existing account. In either case, our AML Compliance Officer will be notified so that we can determine whether we should report the situation to AML/CFT

5.5. Customer Identification Program

We do not open or maintain “customer accounts” we do not establish formal relationships with “customers” for the purpose of effecting transactions in securities. If in the future the Company elects to open customer accounts or to establish formal relationships with customers for the purpose of effecting transactions in securities, we will first establish, document and ensure the implementation of appropriate CIP procedures.

We will collect information to determine whether any entity opening an account would be excluded as a “customer,” pursuant to the Anti Money Laundering policy of United Kingdom (e.g., documentation of a company’s listing information, licensing or registration of a financial institution in United Kingdom, and status or verification of the authenticity of a government agency or department).

6.6. Required Customer Information

Prior to opening an account, Fort Exbit UAB AML Compliance Officer will collect the following information for all accounts, if applicable, for any person, entity or organization that is opening a new account and whose name is on the account:

  1. The name;
  2. Date of birth (for an individual);
  3. an address, which will be a residential or business street address (for an individual), a Post Office (APO) or Fleet Post Office (FPO) box number, or residential or business street address of next of kin or another contact individual (for an individual who does not have a residential or business street address), or a principal place of business, local office, or other physical location (for a person other than an individual); and
  4. an identification number, which will be a taxpayer identification number (for U.S. persons), or one or more of the following: a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or other similar safeguard.

When opening an account for a foreign business or enterprise that does not have an identification number, we will request alternative government-issued documentation certifying the existence of the business or enterprise.

Customers Who Refuse to Provide Information

If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, Fort Exbit UAB will not open a new account and, after considering the risks involved, consider closing any existing account. In either case, our AML Compliance Person will be notified so that we can determine whether we should report the situation to the appropriate authority.

7.Know Your Customer (KYC)

Know Your Customer (KYC) is a phrase very well known by anyone in a regulated market. This important process allows you to verify that the individual you are dealing with is who they claim. By combining indirect and user provided information, Fort Exbit UAB is able to assess the largest risk factors in online transactions. User documents are scanned using text and document recognition technology. This instant process allows you to quickly assess who you are dealing with and get down to business.

8.Verifying Customers Information

Fort Exbit UAB will analyze the information we obtain to determine whether the information is sufficient to form a reasonable belief that we know the true identity of the customer (e.g., whether the information is logical or contains inconsistencies).

We will verify customer identity through documentary means, non-documentary means or both. [Tailor the sentence to your actual situation.] We will use documents to verify customer identity when appropriate documents are available. In light of the increased instances of identity fraud, we will supplement the use of documentary evidence by using the non-documentary means described below whenever necessary. We may also use non-documentary means, if we are still uncertain about whether we know the true identity of the customer. In verifying the information, we will consider whether the identifying information that we receive, such as the

  1. customer’s name,
  2. street address,
  3. zip code,
  4. telephone number (if provided),
  5. date of birth
  6. and Social Security number,

All these information will allow us to determine that we have a reasonable belief that we know the true identity of the customer (e.g., whether the information is logical or contains inconsistencies).

9.Lack of Verification

Fort Exbit UAB: When we cannot form a reasonable belief that we know the true identity of a customer, we will do the following:

  1. Not open an account;
  2. impose terms under which a customer may conduct transactions while we attempt to verify the customer’s identity;
  3. Close an account after attempts to verify a customer’s identity fail; and
  4. Determine whether it is necessary to file a complaints in accordance with applicable laws and regulations.

10.Conducting Ongoing Monitoring to Identify and Report Suspicious Transactions

We will conduct ongoing monitoring to identify and report suspicious transactions and, on a risk basis, maintain and update customer information, including information regarding the beneficial ownership of legal entity customers, using the customer risk profile as a baseline against which customer activity is assessed for suspicious transaction reporting.

11.Recordkeeping

We will document our verification, including all identifying information provided by a customer, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. We will keep records containing a description of any document that we relied on to verify a customer’s identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuance and expiration date. With respect to non-documentary verification, we will retain documents that describe the methods and the results of any measures we took to verify the identity of a customer.

We will also keep records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained. We will retain records of all identification information for five years after the account has been closed; we will retain records made about verification of the customer's identity for five years after the record is made

12.Monitoring Accounts for Suspicious Activity

We will monitor account activity for unusual size, volume, pattern or type of transactions, taking into account risk factors and red flags that are appropriate to our business. Monitoring will be conducted through the automated monitoring. The Fort Exbit UAB AML Compliance officer or his or her designee will be responsible for this monitoring, we will review any activity that our monitoring system detects, will determine whether any additional steps are required, will document when and how this monitoring is carried out, and will report suspicious activities to the appropriate authorities.

13.Contact Us

If you have any questions about this privacy policy please contact us at [email protected]

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