Anti Money Laundering Policy

Introduction

This document describes TRANZZO LTD (further TRANZZO) policy and commitment to the detection and prevention of any money-laundering or terrorism financing activity within the products and services offered by TRANZZO to its customers.

Definition

“Money Laundering” is the participation in any transaction that seeks to conceal or disguise the nature or origin of funds derived from illegal activities such as, for example, fraud, corruption, organised crime, or terrorism etc. Predicate offences for money laundering are defined by national law. The money laundering process consists of three stages:

1. Placement. Physically depositing cash into banks and non-bank financial institutions such as currency exchanges; converting cash into other financial instruments such as by purchasing monetary instruments (travellers’ checks, payment orders); or using cash to purchase high-value goods that can be resold. Launderers often seek to deposit cash into banks in countries with low financial market regulation demands and then transfer these funds to banks in regulated environments as “clean”. Smurfing - a form of Placement where the launderer makes many small cash deposits instead of a large one to evade local regulatory reporting requirements applicable to cash transactions.
   
2. Layering. Separating the proceeds of criminal activity from their source through the use of layers of financial transactions (multiple transfers of funds among financial institutions, early surrender of an annuity without regard to penalties, cash collateralised loans, LCs with false invoices/bills of lading, etc.) to disguise the origin of the funds, disrupt any audit trail, and provide anonymity. Launderers want to move funds around, changing both the form of the funds and their location in order to make it more complicated for law enforcement authorities to trace “dirty” money.
   
3. Integration. Placing the laundered proceeds back into the economy in such a way that they re- enter the financial system as apparently legitimate funds.

This Policy is supported by a set of program covering the implementation of the following areas:

• The adoption of a risk-based approach
• Know Your Client (KYC) Policy and Customer Due Diligence
• Customer activity monitoring
• Record Keeping

The Adoption of a Risk Based Approach

1. Country Risk

In conjunction with other risk factors, provides useful information as to potential money laundering risks. Factors that may result in a determination that a country poses a heightened risk include:

• Countries subject to sanctions, embargoes or similar measures;
• Countries identified by the Financial Action Task Force (“FATF”) as non cooperative in the fight against money laundering or identified by credible sources as lacking appropriate money laundering laws and regulations;
• Countries identified by credible sources as providing funding or support for terrorist activities.

2. Customer Risk

There is no universal consensus as to which customers pose a high risk, but the below listed characteristics of customers have been identified with potentially heightened money laundering risks:

• Armament manufacturers;
• Cash intensive business;
• Unregulated charities and other unregulated “non-profit” organisations.

Customer Acceptance

TRANZZO obtains sufficient information in order to undertake its risk assessment and determine the potential exposure to ML/FT risks and to justify the applicable level of due diligence to mitigate those risks.

TRANZZO obtains sufficient detail from merchant applications to enable it to assess the risks. Relevant information contained therein might be corroborated by either appropriate electronic means or by suitable documentation. Initial due diligence should be supported by the use of transaction monitoring to assist in the identification of activity (such as volume of transactions, etc.) that may be indicative of money laundering and other illegal activity.

Therefore, on a Risk Based Approach, relevant evidential documentation must be requested where a change in circumstances in respect of their trading patterns, amounts and currencies, frequency or recipients occur. Prior to the onboarding of a legal entity, the below minimum information must be obtained by the Tranzzo and then verified with documentation or online checks if applicable:

• Company Name and Trading name (if different);
• Company registration number and date of incorporation;
• Business telephone number and email address;
• Business website(s);
• Description of main business including products and services;
• Directors: names, date of birth, nationality;
• UBOs (Ultimate Beneficial Owners) down to 25%: names, date of birth, nationality, percentage owned;

Tranzzo collect the below listed verification documents for legal entities prior to the onboarding in order to fully meet its Compliance standards:

Applying Company:

• Filled in Application Form, signed by Director or authorised person;
• Certificate of Incorporation / Registration;
• Memorandum / Articles of Association;
• Directors Register;
• Recent Certificate of Good Standing (dated not older than 3 months); if the company is incorporated in an offshore jurisdiction, Certificate of incumbency additionally to be collected;
• UBOs Passport Copies (colour copies) and Recent Utility Bill;
• Directors Passport Copies (colour copies) and Recent Utility Bill;
• Company proof of address (utility bill or bank statement in the company’s name, issued within the last 3 months);
• Company structure of layout of all legal entities involved;
• License to operate the activity, if applicable. (e.g. gaming license);
• Agreement between merchant and license holder if license is not owned by merchant;
• AML/CFT Company Policy (on case by cases basis if the merchant is considered higher risk).

When the owner of the Applying Company is another Company(s) additionally to collect the bellow documentation for the company UBO:

• Certificate of Incorporation / Registration;
• Memorandum & Articles of Association;
• Shareholders Register.

3. Service Risk

Determining the money laundering risks of services should include a consideration of such factors as services identified by regulators, governmental authorities or other credible sources as being potentially high risk for money laundering.

TRANZZO has established non- acceptable use policy which to clearly indicate the business models which are not among the acceptable ones. Those include, but are not limited to:

• Material which incites or promote violence and/or racism;
• Any goods or services that infringe on the intellectual property rights of third parties
• Prepaid or other stored value cards that are not associated with a particular merchant and/or are not limited to purchases of particular products or services;
• Unlicensed gambling services of any type.

Know Your Customer and Customer Due Diligence

TRANZZO is an online operating brokerage company and therefore business relationships between the company and its customers are not established on a face-to-face basis. For customer identification purpose TRANZZO uses electronic data brokers (linked with other in-house checks e.g., identifying duplicate accounts, confirming ownership of bank accounts etc.) to provide identity verification. This will be used to determine and document the true identity of customers to obtain background information on customers as well as purpose and intended nature of their business to us.

TRANZZO shall obtain and document any additional customer information, commensurate with the assessment of the money laundering risk using Risk Based Approach.

TRANZZO shall identify whether the customer is acting on behalf of another natural person or legal entity as trustee, nominee or professional intermediary. In such case obligatory precondition of customer serve is receipt of satisfactory evidence of the identity of any intermediaries and of the persons on whose behalf they are acting, as well as the nature of the trust arrangements in place.

Record Keeping

Records must be kept of all documents obtained for the purpose of customer identification (KYC policy requirements) and all data of each transaction as well as other information related to money laundering matters in accordance with the applicable anti-money laundering laws/regulations. That includes files on suspicious activity reports, documentation of AML account monitoring, etc. Those records must be kept for a minimum of 5 years.

TRANZZO LTD
Registration Nr. 11075606
128 City Road, London, England, EC1V 2NX
tel. +44 203 8683167
email: partner@tranzzo.com

Accepted: 24.01.2018