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Effective date: 01.02.2020
1.1. The phrase “money laundering” covers all procedures to conceal the origins of criminal proceeds so that they appear to originate from a legitimate source. Investizo LTD. (“Company”) aims to detect, manage and mitigate the risks associated with money laundering and the financing of terrorism. The Company has introduced strict policy aimed on the detection, risk prevention or mitigation in respect of any suspicious activities performed by customers.
1.2. The Company is required to constantly monitor its level of exposure to the risk of money laundering and the financing of terrorism.
1.3. The Company believes that if it knows its client well and understands its instructions thoroughly, it will be better placed to assess risks and spot suspicious activities.
2.2. Effective Customer Due Diligence (”CDD”) measures are essential to the management of money laundering and terrorist financing risk. CDD means identifying the customer and verifying their true identity on the basis of documents, data or information both at the moment of starting a business relationship with customer and on an ongoing basis. The customer identification and verification procedures require, first, the collection of data and, second, attempts to verify that data.
2.2. During the Client’s Portal registration process, before obtaining any service from the Company or making any payments to the Company, an individual customers provide the following identification information to the Company:
2.3. During the Client’s Portal registration process, before obtaining any service from the Company or making any payments to the Company, a corporate customers provide the following identification information to the Company:
2.4. After receiving the identification information the Company’s staff should verify this information requesting the appropriate documents. The verification process can take up to 4 business days after all requested documents are provided by the Client.
2.5. Appropriate documents for verifying the identity of customer include, but are not limited to, the following:
2.6. To verify proof of address of the customer the Company requires one of the following to be provided, in the same correct name of the customer:
2.7. When making a funds deposit or funds withdrawal via credit/debit card a customer is required to provide a scanned copy or photo of the credit/debit card (front and back side). The front side of credit/debit card should show the cardholder's full name, the expiry date and the first six and the last four digits of the card number (the rest of the digits may be covered). The copy or scan of the reverse side of credit/debit card should show the cardholder's signature, but the CVC2/CVV2 code must be masked.
2.8. If an existing customer either refuses to provide the information described above or if a customer has intentionally provided misleading information, the Company, after considering the risks involved, will consider closing any of an existing customer’s account.
2.9. The Regulations measures require further research and identification of customers who may pose a potentially high risk of money laundering/terrorism financing. If the Company has assessed that the business relationship with a customer pose a high risk it will apply the following additional measures:
2.10. When obtaining information to verify the customer’s statements about source of funds or wealth, the Company’s staff will most often ask for and scrutinize details of the person’s employment status or business/occupation. The Company’s staff will ask for whatever additional data or proof of that employment/occupation that may be deemed necessary in the situation, particularly the appropriate confirming documents (employment agreements, bank statements, letter from employer or business etc.).
2.11. The Company will conduct ongoing customer due diligence and account monitoring for all business relationships with customers. It particularly involves regularly reviewing and refreshing Company’s view of what its customers are doing, the level of risk they pose, and whether anything is inconsistent with information or beliefs previously held about the customer. It can also include anything that appears to be a material change in the nature or purpose of the customer’s business relationship with Company.
3.1. Investizo LTD. requires all deposits, where the name of the originating customer is present, to come from the name matching the name of the customer in our records. Third party payments are not accepted.
As for withdrawals, money may be withdrawn from the same account and by the same way it was received. For withdrawals where the name of the recipient is present, the name must exactly match the name of the customer in our records. If the deposit was made by wire transfer, funds may be withdrawn only by wire transfer to the same bank and to the same account from which it originated. If the deposit was made by means of electronic currency transfer, funds may be withdrawn only by the means of electronic currency transfer through the same system and to the same account from which it originated. To comply with the AML procedures, funds withdrawals have to be made solely in the same currency that was used to make a deposit.
4.1. The Company is committed to combating money laundering and for this reason it has appointed a dedicated Anti-Money Laundering Compliance Officer (the “AMLCO”) who is accountable to the Board of Directors and Senior Management of the Company.
4.2. AML Compliance Officer’s responsibilities include:
4.3. All Company employees, managers and directors must be aware of this policy.
4.4. Employees, managers and directors who are engaged in AML related duties must be suitably vetted. This includes a criminal check done at the time of employment and monitoring during employment. Any violation of this policy or an AML program must be reported in confidence to the AML Compliance Officer, unless the violation implicates the AML Compliance Officer, in which case the employee must report the violation to the Chief Executive Officer
4.5. Employees who work in areas that are susceptible to money laundering or financing terrorism schemes must be trained in how to comply with this policy or the AML program. This includes knowing how to be alert to money laundering and terrorism financing risks and what to do once the risks are identified.
4.6. The Company provides AML training to employees who will be dealing with customers or will be involved in any AML checking, verification or monitoring processes. The Company may conduct its training internally or hire external third party consultants.
4.7. Each person employed within the Company is assigned a supervisor who teaches him or her in relation to all policies, procedures, customer documentation forms and requirements, forex markets, trading platforms, etc. There is a training plan for each new employee and tests which are being held for 2-3 months (depending on level within the business).
4.8. The Company’s AML training programmes is aimed to ensure its employees to receive appropriate training level with regards to any possible AML/TF risks.
4.9. The Company’s AML and risk awareness training includes the following content:
For further AML enquiries please contact us at firstname.lastname@example.org