Introduction
The website of marnic-group.pro is owned by MARNIC FINANCIAL CONSULTANTS LTD, an authorized financial services provider, License No 46886, Registration Number:2015 / 331240 / 07.
1. Scope
1.1 The AML & KYC Policy (the ‘Policy’) is provided by the Company to its Clients in order to assist them to understand the regulations and the policies followed by the Company in order to comply with the anti-money laundering and terrorist financing laws, as well as Know Your Client requirements.
2. Anti-Money Laundering (AML) Policy
2.1 The Prevention of money laundering and terrorist financing is a significant responsibility and aim of the Company. The Company is fully committed to preventing any money laundering activities through its services and as such, in the Company’s measures to combat money laundering, we ensure that the Company:
2.2 Identifies and report any suspicious transactions through the appropriate channels;
2.3 Gets to know its Clients through the request of legal documentation;
2.4 Upholds all transaction records of Clients for a minimum of 5 years, following termination of the Agreement;
2.5 Guarantees that all staff is sufficiently qualified in the appropriate KYC and AML procedures and in what constitutes suspect activity and reporting such activity to the appropriate personnel;
2.6 Carries on continuous monitoring of any reported suspicious activities;
2.7 Uses all resources available, within the Company and in other countries to ensure that all suspicious activities have been investigated
2.8 The Company reserves the right to request all necessary Verification Documents from the Client before the expiry of the Probation Period, described in the Commencement of the Terms and Conditions and the Right to Cancel section of the Client’s Agreement. Further, the Company reserves the right to request additional or updated documentation if necessary.
2.9 The Company is obliged to report all suspicious transactions to the appropriate authorities and is forbidden from informing the Client that they have been written for suspicious account activity. Account abuse may result in criminal prosecution.
2.10 The Company reserves the right to refuse to process a transfer at any stage if it believes/suspects it to be connected in any way to criminal activity or money laundering.
2.11 The Company is strongly opposed to providing business to Clients whose funds are sourced from criminal activity.
3. Know Your Customer (KYC) Policies
3.1 The Company is obliged to confirm and verify the identity of each person who registers on the Company’s system and opens an account with the Firm.
3.2 The Company’s duties to comply with applicable Anti-money laundering & Know Your Customer legislation, the Company requests its Clients to provide certain Verification Documents (which shall typically include but are not limited to, an identity card or passport, proof of residential address such as a recent utility bill, and proof of the Client’s payment method).
3.3 The Company observes the construction of the Client’s economic profile, in order to get a sufficient understanding of the Clients business activities, and source of funds, as well as ensure that the Company understands the investment objectives of its customers and is aware of their relevant trading knowledge and experience.
3.4 Among other things, the following regulations are considered as a part of the Know Your Customer procedure:
3.4.1 The Company will not accept as Clients, parties that cannot make a well-informed and reasonable determination as to the activities in which they are engaged;
3.4.2 The Company will not accept as Clients persons engaged in unethical behavior or in illegal policy;
3.4.3 The Company will accept only those new Clients who complete the appropriate Account Opening Procedure and provide the Company with all necessary Verification Documents and information to the satisfaction of the Company. The Client should provide the Company with the following documents (‘Verification Documents’) and information: - Proof of the Client’s Identity* – To prove his/her identity, the Client is obliged to provide the Company with a copy of his/her Passport or National Identification Card/Driving License.
3.4.4 3.4.4 Document has to be valid;
3.4.5 Copy has to be in colour (black and white copies are not acceptable);
3.4.6 All information on the document must be clear and visible - proof of the Client’s Residential Address* - In order to prove his/her residential address, the Client is obliged to provide the Company with a copy of his/her recent Utility Bill (gas, water, electric) or a bank statement issued in his/her name. The issuing date of the document cannot be older than 3 months. - Proof of the Client’s Payment Method - depends on the payment method, i.e. a credit/debit card copy (the first 4 and the last 4 digits must be visible, expiry date must be shown also, and the CVV code should be covered) or a proof of bank transfer - Information and data that are used for the construction of the Client’s economic profile;
3.4.7 The Company reserves the right to complete the verification process during the Probation Period, as specified in the Commencement of the Terms and Conditions and the Right to Cancel section of the Client’s Agreement. If for whatever reason, the Client refuses to provide the Company with the required information in a timely manner, the Company reserves the right to terminate the agreement in compliance with the Termination and Default section of the Client’s Agreement.
3.4.8 The Company takes no responsibility for any possible delays where the Client’s Verification Documents are outstanding.
3.4.9 The Company will not accept as Clients, persons unwilling to provide sufficient documents/data and information as provided in the Agreement.
3.4.10 If a Client fails or declines to submit, within a reasonable timeframe set by the Company, the required documents, data and information requested by the Firm; the Company is entitled to terminate the business relationship and close all Client’s accounts;
during the business relationship, additional documents may be requested by the Company and/or an update of the existing documents. If the Client denies providing these documents without any legitimate reason, the Company is entitled to terminate the business relationship and close all Client’s Account(s), in compliance with the Termination and Default section of the Client’s Agreement.
3.4.11 Client hereby agrees that the data collected and obtained from the Client may be used by the Company, its agents and service providers and regulatory bodies to conduct identity, fraud, AML, credit and other checks and the Client hereby authorizes the above entities to conduct the above checks. The Company shall use all the information obtained from the Client in accordance with its Privacy Policy.
4. Track
4.1 The electronic tracking of transactions is a matter that is receiving a great deal of attention from the financial services industry.
An increasing number of transactions are being undertaken electronically, without any human intervention, providing those involved in money laundering with plenty of opportunities to launder money and remain concealed.
4.2 Transactions accomplished for the Client are compared and considered against the anticipated movement of the account, the standard turnover, business and customer data/information held and according to the economic profile of the customer.
Substantial deviations are investigated and the findings are recorded in the file of the Client.
4.3 There is recognition by the industry and regulators that the electronic tracking of transactions can provide some protection in dealing with this risk. A tracking system can provide an effective way of identifying potential money laundering transactions.