POORDI TN 3-75 KESKLINNA LINNAOSA, TALLINN HARJU MAAKOND 10156

Anti Money Laundering (“AML”) Policy

The purpose of the Anti-Money Laundering Policy (“AML Policy”) within Ofinans OÜ, is to reduce the risk by evaluating the customers, transactions and services within the Ofinans OÜ, with a risk-based approach, to prevent the laundering of income and the creation of an environment that will facilitate the financing of terrorism and in this context, to raise awareness of the employees and to obtain information and inform the customers that the Company conducts its activities in accordance with the legislation in force, in particular the Law dated as 14th of January 2008 No. 4/2008 on the Prevention of Laundering Proceeds of Crime and the Law on the Prevention of the Financing of Terrorism. Under this AML Policy, Customers, whose recognition policy is applied within the framework of the company’s activities, refer to the real and legal person who is a member of the website (“Site”) accessed from www.ofinans.com and benefits from the services offered on the Site and in return accepts the matters in this AML Policy.

      (“Customer”) The company will take the following measures to achieve these objectives:

  • Verifying the identity of all new and existing Customers to a reasonable level
  • Applying a risk-based approach to monitoring the taxation and financing transactions of the customer
  • Notifying any suspicious transaction carried out by the customers to the relevant institutions and organizations within the framework of the current legislation and recording the Transactions within the framework of this AML Policy
  • Establishing the AML Department to coordinate the enforcement andapplicability of the AML Policy with Ofinans OÜ. has prepared its AML Policy in accordance with international standards and current legislation.
  1. In accordance with the Know-Your-Customer Policy (KYC Policy) of Ofinans OÜ, www.ofinans.com

It applies the following measures within the framework of the current legislation and other internal policies.

  • Verification of customer identity
  • Taking measures to identify the beneficiary as a result of the transactions carried out by the customer
  • Obtaining satisfactory information about the purpose and nature of the transaction the customer wants to do.
  • Monitoring and comparing the Customer with the Customer profile, with the transactions performed by the Customer, throughout customer relations.
  • Monitoring high risk Customers, transactions and other customers that require special attention
  1. Risk Analysis and Monitoring Ofinans OÜ, adopts a risk-based approach in monitoring the financial activities of its customers and can conduct risk analysis with the following methods in order to prevent money laundering and financing of terrorism, and can monitor the relevant Customers within the framework of the information obtained as a result of the risk analysis. This will be done while preparing accounts or tax returns or conducting any other business with the client. The purpose of Risk Analysis, Monitoring andControl activities is to protect, monitor and control Ofinans OÜ, its Customers and the cryptocurrency exchange against risks. In this context, Ofinans OÜ constantly monitors the relevant legislation and regulations of crypto money trading and clearing activities, and more frequently controls the customers and transactions, which it qualifies as risk groups. Risk analysis,monitoring and control activities to be carried out within Ofinans OÜ are carried out under the responsibility of the Risk Analysis and Control Department. The Company takes the following measures within the scope of monitoring and control activities.
  • Monitoring and controlling customers and transactions in high risk group
  • Monitoring and control of complex and unusual transactions
  • Monitoring and control of transactions with high risk countries
  • Analysis of whether the transactions performed by customers exceed a predetermined limit or are consistent with the customer profile
  • Checking, completing and updating customer information and documents
  • Keeping written and mandatory information regarding cryptocurrency trading and transfer.
  • Monitoring whether a transaction carried out by the customer is inaccordance with the information regarding the transaction in question, Ofinans OÜ has determined the Customer and transactions in the high-risk group as follows:
  • The total amount of a single cryptocurrency trading or multiple linked transactions

If it is equal or more than 250.000.-USD;

  • The total amount of a single cryptocurrency swap transaction or multiple linked transactions

If it is equal or more than 250.000.-USD;

  • Regardless of the monetary amount, in cases requiring suspicious transaction reporting within the framework of current legislation;
  • Regardless of the monetary amount, in case of doubt about the accuracy and adequacy of previously acquired credentials;
  • Customers who perform complex transactions that have the potential to hide third party beneficiaries
  • In cases where money resources cannot be easily verified
  • Unusual transactions with any economic or visible legitimate purpose
  1. Suspicious Transaction Reporting Within the framework of the services provided by Ofinans OÜ, in cases that raise suspicion about money laundering and the financing of terrorism, transactions determined as suspicious transactions as a result of the necessary investigations (“Suspicious”,”Transaction”), in accordance with the legislation in force, the Financial Crimes Investigation Board Presidency (“MABEB”). Suspicious Transactions are reported directly to the Board regardless of the amounts. The real persons who carry out the Suspicious Transaction and their legal representatives, the managers and staff who do not comply with the obligation to report the Suspicious Transaction will be responsible for all kinds of administrative and criminal sanctions. While performing their duties, Employees will be warned within the framework of the relevant legal obligations and will be made to act in this direction. Suspicious Transactions to be detected and reported are as follows, without limitation;
  • Transactions without legitimate legal and economic purposes
  • Transactions in which the Customer refrains from providing information and documents or is unwilling to
  • Transactions required to be reported for liabilities defined in the current legislation
  • Transactions where customers provide misleading and unconfirmed information

Transactions with accounts in regions where cryptocurrency buying, selling and clearing transactions are prohibited or restricted

  • Transactions that are not listed here and that are/will be considered as suspicious within the scope of the legislation in force,
  1. Education : Ofinans OÜ, by creating a corporate culture, fulfills all its liabilities within the scope of training with the personnel policy and procedures it has issued in accordance with the current legislation. The trainings to be given to the personnel within the framework of the obligations will at least cover the following issues;
  • Laundering of terrorist financing resources arising from crime
  • Determination of laundering stages and methods of proceeds of crime and case studies on this subject
  • Legislation on prevention of laundering and financing of terrorism arising from crime
  • Risk areas
  • Corporate policies and procedures
  • Principles regarding customer verification
  • Principles regarding suspicious transaction reporting
  • Obligation to preserve and submit
  • Obligation to provide information and documents
  • Sanctions to be applied in case of breach of obligations
  • International regulations on combating money laundering and terrorist financing
  1. Internal Audit

Ofinans OÜ is obliged to periodically audit whether its activities related to laws, regulations and communiqués against money laundering and terrorismfinancing comply with the current legislation, Ofinans OÜ policies and procedures. The Risk Analysis and Control Department is obliged to compile and report statistical data as a result of the internal audit activity regularly carried out in accordance with the relevant legislation mentioned above. For more information, please contact us at [email protected]

Regards,

Ofinans OÜ

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