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    Aml Policy

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    augustocesarmolinayanes

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    © All Rights Reserved
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    Aml Policy

    Uploaded by

    augustocesarmolinayanes
    3 views6 pages

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    Copyright:

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    3 views6 pages

    Aml Policy

    Uploaded by

    augustocesarmolinayanes

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 6

    ANTI-MONEY LAUNDERING

    POLICY
    (UPDATED 14 August 2023)
    Contents

    Introduction 2

    General Requirements for the Company 2

    Identity Verification 3

    Anti-Money Laundering Compliance Officer 3

    Transaction Monitoring 4

    Risk Assessment 4

    Sanctions 5
    Introduction
    StormGain LLC (or “the Company”) Anti-Money Laundering and Know Your
    Customer Policy (hereinafter - the “AML/KYC Policy”) is designed to prevent
    and mitigate possible risks of the Company being involved in any kind of
    illegal activity.

    This document is a short extract of key principles from the Companies Internal
    Policy and should not be viewed as a full AML/KYC Policy.

    Domestic and international regulations require StormGain LLC to implement


    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 take action in case of any
    form of suspicious activity on the part of its clients.

    The AML/KYC Policy covers the following matters:


    • appointing an Anti-Money Laundering Compliance Officer (AMLCO)
    and making sure that employees know to report any suspicious
    activity to them;
    • identifying the responsibilities of senior managers and providing
    them with regular information on money laundering risks;
    • training employees on their anti-money laundering responsibilities;
    • documenting and updating anti-money laundering policies, controls
    and procedures;
    • introducing measures to make sure that the risk of money laundering
    is taken into account in the day-to-day business operations;
    • Forwarding/reporting all sustained suspicions to the appropriate
    authority;
    • Promptly responding to all communication from the appropriate
    authority.

    General Requirements for the Company


    Before the Company can execute any transaction for any new client, a
    number of procedures need to be in place and carried out:
    • AML procedures, including customer identification, record-keeping,
    discovering and monitoring of unusual or suspicious transactions
    and, as appropriate, internal/external reporting and control;
    • ensuring that all employees know and understand their
    responsibilities and the Company’s procedures;
    • ensure that appropriate training is undertaken;
    • all relevant requests from outside sources are forwarded directly to
    the AMLCO.

    Identity Verification
    Whenever the Company requests and receives supporting documents
    related to a new client’s identity, it needs to be completely satisfied that they
    demonstrate the existence of the new client as a real natural or legal person
    and that the client is indeed who they say they are.

    Although the Company will at times rely on third party sources as part of its
    fact-checking procedure when onboarding clients, the Company bears the
    ultimate legal responsibility for the checks being conducted accurately.

    Client’s identification information will be collected, securely stored, shared


    and protected strictly in accordance with the Company’s Privacy Policy and
    related regulations that correspond to the GDPR requirements.

    Anti-Money Laundering Compliance Officer


    The AMLCO is ultimately responsible for implementing regulations concerning
    Anti-Money Laundering. For the sake of ease of navigating this document
    ‘Compliance Officer’ and ‘AMLCO’ refer to the same person; however, the
    specific tasks of each role are different.

    As noted above, the AMLCO is a person of authority with access to any and all
    relevant information for the performance of their duties.

    You can contact the Company’s AMLCO department online::


    https://support.stormgain.com
    Transaction Monitoring
    The constant monitoring of the clients’ accounts and transactions is an
    imperative element in effectively controlling the risk of Money Laundering and
    Terrorist Financing. In this respect, the AMLCO shall be responsible for
    maintaining as well as developing the on-going monitoring process of the
    Company.

    Risk Assessment
    The Company shall apply appropriate measures and procedures by adopting
    a risk-based approach, so as to focus its efforts in those areas where the risk
    of Money Laundering and Terrorist Financing appears to be comparatively
    higher.

    Further, the AMLCO shall monitor and evaluate the effectiveness of the
    measures and procedures of this Policy on an on-going basis.

    The adopted risk-based approach that is followed by the Company and


    described in the full AML Policy has the following general characteristics:
    • Recognizes that the money-laundering or terrorist financing threat
    varies across clients, countries, services and financial instruments;
    • allows the board of directors to differentiate between clients of the
    Company in a way that matches the risk of their particular business;
    • allows the board to apply its own approach in formulation of policies,
    procedures and controls in response to the Company’s particular
    circumstances and characteristics;
    • helps to produce a more cost-effective and efficient system;
    • promotes prioritization of effort and actions of the Company in
    response to the likelihood of Money Laundering and Terrorist Financing
    occurring through the use of the Company’s services.

    The risk-based approach adopted by the Company, and described in the


    Policy, involves specific measures and procedures in assessing the most cost
    effective and appropriate way to identify and manage the Money Laundering
    and Terrorist Financing risks faced by the Company.
    Sanctions
    The Company is prohibited from transacting with individuals, companies and
    countries that are under international sanctions. The Company will therefore
    screen all new and existing clients against the United Nations, European Union,
    UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists.

    The Company does not provide services to persons residing in:


    ● USA
    ● Japan
    ● Austria
    ● Afghanistan
    ● Bosnia and Herzegovina
    ● Burundi
    ● Iraq
    ● Central African Republic
    ● Congo
    ● Guinea
    ● Guinea-Bissau
    ● Syria
    ● Haiti
    ● Lebanon
    ● Libya
    ● Mali
    ● Iran
    ● North Korea
    ● British Columbia
    ● Quebec
    ● Myanmar
    ● Netherlands
    ● Nicaragua
    ● Serbia
    ● Somalia
    ● South Sudan
    ● Sudan
    ● Tunisia
    ● Yemen
    ● Zimbabwe
    The above list may be updated at any time with or without updating this document
    by a decision of the Compliance officer.

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