The document describes Uniworc LTD’s policy against money washing and its involvement in identifying and preventing any activity related to money washing and terrorist financing and the possibility of using own products and services to wash money.
Money washing is a financial transaction whose purpose is to conceal the source of funds obtained illegally (fraud, corruption, organized crime, terrorism, etc.). The main crimes related to money washing are determined by law. The money washing process takes place in three stages.
Accommodation. This is the physical placement of cash in banks and non-bank financial and credit institutions such as currency exchange offices, the conversion of funds into other financial instruments, for example, into payment orders or traveler's checks; using cash to pay for expensive goods that can later be sold.For washing money , criminals usually choose foreign banks with a lack of legal norms or insufficient legislation. Their main aim is to find subsequent placement in regulated environments and make them as “clean” ones.
Lamination. Separation of illegal income from their source by creating layers of financial transactions (multiple transfers of funds between financial institutions, processing cash credits, using fake invoices, etc.) aimed at hiding the true source of income and masking the verified trace of these income , as well as in order to ensure anonymity. Criminals transfer funds change their shape and location. Thus, various financial transactions are stacked one to the another and make it difficult for law enforcement agencies to track “dirty” money.
Integration. During integration, washed money is puted back into the economy. Thus, they enter the banking system under the guise of honestly earned income.
The policy includes the following measures:
- Application of a risk-based approach;
- Compliance with due diligence and the “Know Your Customer” policy;
- Monitoring and reporting of suspicious transactions / activities;
APPLICATION OF A RISK-BASED APPROACH
Identification of possible money washing risks during transactions and working with clients allows Uniworc LTD to take appropriate measures to control and reduce these risks. The Company will receive and document any additional information about the Customers and evaluate the degree of money washing risk using a risk-based approach. Traditionally, the following types of risk are distinguished for risk assessment:
RISK BY COUNTRY
Country risk, combined with other factors, provides useful information regarding the potential risk of money washing and terrorist financing. The main factors that increase the level of risk in the country are:
- Countries –subjects to sanctions, embargoes or similar measures;
- FATF blacklisted countries that do not cooperate in the global fight against money washing and the financing of terrorism or have imperfect legislation that does not have special policy against washing money ;
- The availability of reliable information that the country is financing or supporting terrorist activities.
It is impossible to say which customers pose the highest risk. And yet, the following characteristics of customer activities have been identified as being a potential hazard:
- Weapons production;
- Business with a high share of cash;
- Non-regulated charities and other non-profit organizations.
RISK RELATED TO SPECIFIC ACTIVITIES
In the general assessment of the risk of money washing, certain types of activities of financial organizations in rendering services to their clients, which are included in the list of regulatory and state foundation, as well as other reliable sources, as potentially dangerous activities in terms of money washing, should be taken into account.
POLICY “KNOW YOUR CUSTOMER” (KYC)
To identify the client, the Company carries out internal checks (for example, identifying duplicate accounts (multi-accounts), confirming the identity of the owner of the bank account, E-wallet, etc.), in order to determine and document the identity of the Client and obtain all the necessary information about the Client, goals and the nature of his planned activities. Uniworc Ltd. shall establish whether the Client acts on behalf of another natural or legal person as a representative (intermediary, trustee). In such cases, a prerequisite for cooperation with the Client is the provision of documents proving the identity of the person he represents, as well as an agreement confirming the establishment of a trust between these persons.
MONITORING AND REPORTING SUSPECT OPERATIONS OR ACTIVITIES
Uniworc Ltd. will track customer activity in order to detect any suspicious (or fraudulent) activity. Along with the use of an automated monitoring system, the Company will also, if necessary, attract its own employees and outsourcing providers to carry out additional monitoring of operations independently.
The Company has implemented an official system for reporting suspicious activity and a procedure that will allow all employees of Uniworc Ltd. to report to the responsible financial monitoring officer any suspicious activity related to money washing or terrorist financing. The system includes three stages:
- All staff must do control with respect to any unusual or suspicious transactions / activities;
- Suspicious transaction / activity reports must be submitted in accordance with applicable laws / regulations of the relevant legislation;
- All information about suspicious transactions / activities will be provided to the responsible financial monitoring officer every month.
All documents received for the purpose of identifying the client in accordance with the requirements of the KYC policy, all transaction data, as well as other information related to money laundering cases, including reports on suspicious activity and documentation related to monitoring accounts, will be stored in the Company’s archive in accordance to the current law / regulation on combating money washing for at least 5 years.