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Anti-money laundering policy

The following describes the policy of “InvoiceBox” group of companies (“InvoiceBox” OÜ, “InvoiceBox.US” Inc., “USC” LLC) (hereinafter referred to as the “Company”) to combat money laundering and its involvement in the detection and prevention of any activities related to money laundering and terrorist financing; and the possibility of using their products and services for the purpose of money laundering.

Definition

Money laundering is a financial transaction whose purpose is to conceal the source of illegally obtained funds (fraud, corruption, organized crime, terrorism, etc.). The main crimes related to money laundering are determined by law. The process of money laundering occurs in three stages.

Placement 

This is the physical placement of cash in banks and non-bank financial institutions such as currency exchange offices, the conversion of cash into other financial instruments, for example, payment orders or traveler's checks; the use of cash to pay for expensive goods that can later be sold. For money laundering, criminals, as a rule, choose foreign banks with a lack of legal norms or insufficient anti-money laundering legislation with a view to their subsequent placement in regulated environments under the pretence of “clean”.

Layering

Separation of illegal incomes from their source by creating layers of financial transactions (numerous transfers of funds between financial institutions, cash loans formalization, using fake invoices, bills, etc.) aimed at concealing the true source of income and disguising the trace of these revenues, as well as to ensure anonymity. Criminals transfer funds, change their form and location. Thus, various financial operations are layered on top of one another and make it difficult for law enforcement agencies to track “dirty” money;

Integration

During integration, laundered money is placed back into the economy. Thus, they enter the banking system under the guise of honestly earned income.

Anti-money laundering policy involves the following activities:

  • Applying a risk-based approach;
  • Compliance with due diligence and Know Your Customer policies;
  • Monitoring and reporting about suspicious transactions/activities;
  • Accounting.

Applying a risk-based approach

Identification of possible risks of money laundering during transactions and work with customers allows the Company to take appropriate measures to control and reduce these risks. Traditionally, the following types of risk are identified for risk assessment:

Country Risk

Country risk, combined with other factors, provides useful information on the potential risk of money laundering and terrorist financing. The main factors that increase the level of country risk are:

  • Countries that are subjects to sanctions, embargoes or similar measures;
  • Countries included in the black list of FATF as not cooperating in the global anti-money laundering and financing of terrorism or having imperfect legislation, which lacks special agencies to combat money laundering;
  • Availability of reliable information that a country finances or supports terrorist activities.

Customer risk

It is impossible to say with certainty which customers are the most at risk. And yet, the following characteristics of customer activity were identified as representing a potential hazard:

  • Arms production;
  • Business with a high proportion of cash;
  • Unregulated charity and other non-profit organizations.

Risk associated with the implementation of a certain type of activity

In a general assessment of the risk of money laundering, certain types of activities of financial organizations providing services to their customers should be taken into account, which are included in the list by regulatory authorities and other reliable sources as a potentially dangerous activity in terms of money laundering

Due diligence and Know Your Customer Policy

InvoiceBox group of companies is an online agent for the organization of electronic sales, therefore, any cooperation of the company with its customers is in absentia. To identify a customer, the Company uses the history of interaction with the customer (transactions, customer support calls), and also carries out other internal checks (for example, analysis of suspicious transactions) in order to identify and document the Customer’s identity and obtain all necessary information about the Customer, goals and the nature of the activity he is planning. The company will receive and document any additional information about Customers and assess the risk of money laundering using a risk-based approach.

The company must determine whether the Customer acts on behalf of another natural or legal entity as a representative (intermediary, trustee). In such cases, a prerequisite for cooperation with the Customer is the provision of the necessary documents proving the identity of the intermediary and the person he represents, as well as documents confirming the establishment of a trust relationship between these persons.

Suspicious transaction/activity monitoring and reporting

In addition to conducting initial due diligence, the Company will monitor customer activity in order to detect any suspicious (or fraudulent) activity. Along with the use of an automated monitoring system, the Company will also need to involve its own employees and outsourcing providers in order to independently conduct additional monitoring of transactions. The company has implemented an internal suspicious activity alert system and a procedure that will allow all employees of the Company to report to the responsible financial monitoring officer any suspicious activity related to money laundering or terrorist financing. The system includes three stages:

  • All personnel should exercise strict control over any unusual or suspicious transactions/activities;
  • All information on suspicious transactions/activities will be provided monthly to the responsible officer.

Accounting

All documents received for the purpose of identifying a customer in accordance with the requirements of the Know Your Customer Policy, all transaction data, as well as other information related to money laundering cases, including reports on suspicious activities and documentation regarding the monitoring of accounts, will be stored in the Company's archive in accordance with the applicable the law/regulations to combat money laundering for at least 5 years.
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