TRANZZO

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, organized crime, or terrorism etc. Predicate offences for money laundering are defined by national law. The money laundering process consists of three stages:

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

THE ADOPTION OF A RISK BASED APPROACH

Identification of the money laundering risks of customers and transactions allow TRANZZO to determine and implement proportionate measures to control and mitigate these risks. Used risk criteria are the following:

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:

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:

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.

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.

CUSTOMER ACTIVITY MONITORING

In addition to conducting initial customer due diligence it isTRANZZO policy to continue to monitor customer activity with a view to identifying any suspicious (or fraudulent) behaviour. The system of monitoring that has been implemented relies on both automated monitoring and, where appropriate, by manual monitoring of transactions by the staff of is TRANZZO  and any outsourced service provider. A series of status fields has been applied to customer accounts indicating their profile within the system, which assists automated monitoring.

TRANZZO  has implemented a regulatory and legally compliant suspicious activity reporting process and procedure that will enable all staff to make a report to the Money Laundering Reporting Officer (MLRO) where they know or they suspect or they have reasonable grounds for knowing or suspecting that a person is engaged in money laundering or terrorist financing. This includes three stages to this process:

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

372 Old Street, London, England, EC1V 9LT

tel. +44 203 8683167

email: [email protected]

Accepted: 24.01.2018