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Internal Control Rules for Anti-Money Laundering (AML) and
Counter-Terrorism Financing (CTF) LLC "Fintopio Virtual Assets"
1. Purpose and Scope
These Internal Control Rules for Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) (hereinafter - AML/CTF) define the procedure for conducting AML/CTF activities in LLC "Fintopio Virtual Assets" (hereinafter - the Company) in accordance with the legislation of the Russian Federation.
2. Key Terms and Definitions
- Money Laundering: actions aimed at giving a legal appearance to money obtained illegally.
- Terrorism Financing: providing or collecting funds with the intention of using them to commit terrorist acts.
- Client: an individual or legal entity with whom the Company enters into business relations.
3. Procedures for Client Identification and Verification
3.1. Client Identification
The Company is obliged to identify all its clients. Client identification includes the collection of the following data:
- for individuals: full name, date and place of birth, citizenship, details of the identity document, residential address;
- for legal entities: name, registration number, tax identification number, legal address, information about the manager.
3.2. Client Verification
Client verification includes checking the accuracy of the provided data:
- comparing data with state registers and databases;
- requesting additional documents and information if necessary.
4. Procedures for Monitoring Client Transactions
4.1. Transaction Monitoring
The Company is obliged to continuously monitor client transactions to identify suspicious transactions:
- analyzing the volume and nature of transactions;
- comparing transactions with the client's profile.
4.2. Criteria for Suspicious Transactions
Suspicious transactions are those that meet the following criteria:
- volumes and frequency of transactions uncharacteristic for the client;
- transactions inconsistent with the client's financial status;
- transactions involving persons from the terrorist list.
5. Procedures for Identifying and Analyzing Suspicious Transactions
5.1. Identifying Suspicious Transactions
Company employees are required to identify suspicious transactions and transmit information about them to the employee responsible for AML/CTF.
5.2. Analyzing Suspicious Transactions
The employee responsible for AML/CTF conducts an analysis of suspicious transactions and decides whether further investigation and notification of the authorized bodies is necessary.
6. Procedures for Reporting to the Federal Financial Monitoring
Service (Rosfinmonitoring)
6.1. Notifying Rosfinmonitoring
The Company is obliged to notify Rosfinmonitoring about identified suspicious transactions in the prescribed manner:
- submitting reports on suspicious transactions through the personal account on the Rosfinmonitoring website;
- providing additional information upon request from Rosfinmonitoring.
7. Risk Assessment and Management
7.1. Risk Assessment
The Company conducts AML/CTF risk assessments on a regular basis:
- analyzing potential risks depending on the type of clients, provided services, and geographical location.
7.2. Risk Management
The Company takes measures to mitigate AML/CTF risks:
- implementing additional client verification procedures;
- limiting transactions with high-risk clients.
8. Documentation and Information Storage
8.1. Documentation
The Company maintains records of all AML/CTF activities, including client identification, verification, and monitoring.
8.2. Information Storage
The storage period for information and documents is at least five years from the date of termination of business relations with the client.
9. Staff Training and Qualification Improvement
9.1. Training Program
The Company develops and implements staff training programs on AML/CTF issues:
- conducting regular training sessions and seminars;
- familiarizing with the latest legislative changes.
9.2. Qualification Improvement
The employee responsible for AML/CTF is required to undergo qualification improvement at least once every two years.
10. Responsibility
10.1. Company Responsibility
The Company is responsible for complying with these Rules and fulfilling the requirements of AML/CTF legislation.
10.2. Employee Responsibility
Company employees are personally responsible for fulfilling their AML/CTF duties.
11. Final Provisions
These Rules come into force upon approval by the Company's management and remain in effect until they are canceled or replaced by new rules.
The Company undertakes to regularly review and update these Rules in accordance with changes in legislation and AML/CTF practices.
