AML/KYC Policy

AZAforex Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of AZAforex being involved in any kind of illegal activity.

Both international and local regulations require AZAforex to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, the proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.

AML/KYC Policy covers the following matters:

1. Verification procedures

2. Sanctions and PEP lists screening.

3. Compliance Officer.

4. Monitoring Transactions.

5. Risk Assessment.

1. Verification procedures

One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, AZAforex establishes its verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.

1.1. Identity verification

AZAforex’s identity verification procedure requires the User to provide AZAforex with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes, AZAforex reserves the right to collect User’s identification information for the AML/KYC Policy purposes.
AZAforex will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and AZAforex reserves the right to investigate certain Users who have been determined to be risky or suspicious.
AZAforex reserves the right to verify User’s identity on an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). Besides, AZAforex reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
User’s identification information will be collected, stored, shared and protected strictly following the AZAforex’s Privacy Policy and related regulations.
Once the User’s identity has been verified, AZAforex can remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

1.2. Card verification

The Users who are intended to use payment cards in connection with the AZAforex’s Services have to pass card verification following instructions available on the AZAforex’s Site.

2. Sanctions and PEP lists screening.

AZAforex screens applicants against recognised Sanctions and Politically Exposed Persons (PEPs) lists. Individuals and legal entities are screened against mentioned lists:/p>

For the screening process performing AZAforex uses WorldCompliance data (provided by LexisNexis) integrated into the proprietary software and supported by World-Check One online search tool (provided by Refinitiv) for manual confirmation.

3. Compliance Officer

The Compliance Officer is the person, duly authorized by AZAforex, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of AZAforex’s anti-money laundering and counter-terrorist financing, including but not limited to:

a. Collecting Users’ identification information. b. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations. c. Monitoring transactions and investigating any significant deviations from normal activity. d. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs. e. Updating risk assessment regularly. f. Providing law enforcement with information as required under the applicable laws and regulations.

The Compliance Officer is entitled to interact with law enforcement, which is involved in the prevention of money laundering, terrorist financing and other illegal activity.

4. Monitoring Transactions

The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, AZAforex relies on data analysis as a risk-assessment and suspicion detection tool. AZAforex performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:

1) Daily check of Users against recognized “blacklists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;

2) Case and document management.

Concerning the AML/KYC Policy, AZAforex will monitor all transactions and it reserves the right to:

The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

5. Risk Assessment

AZAforex, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, AZAforex can ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed following priorities so that the greatest risks receive the highest attention.

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