365 Emoney ® Policy. The Company is commited to prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Money Laundering and Terrorism (Prevention) Act, Money Laundering and Terrorism (Prevention) Act Guidelines, Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Guidelines , FATF recommendations and its implementing regulations. By this way 365 Emoney ® has implemented the highest standards of anti-money laundering (AML) compliance and requires management and employees to adhere to these standards to prevent use of our products and services for money laundering purposes. The program includes client screening and monitoring requirements, “know your customer” policies (including the requirement to establish the identity of beneficial owners), Embargo policies, record keeping requirements, the reporting of suspicious circumstances in accordance with relevant laws, and training.



365 Emoney ® AML Compliance Person. The Company has designated its Compliance Officer (CO) as its Anti-Money Laundering Program Compliance Person (AML Compliance Person), with full responsibility for the firm’s AML program. CO has a working knowledge of compliance requirements and its implementing regulations and is qualified by experience, knowledge and training. The duties of the AML Compliance Person will include monitoring the firm’s compliance with AML obligations, overseeing communication and training for employees. The AML Compliance Person will also ensure that the firm keeps and maintains all of the required AML records and will ensure that Suspicious transaction reports (STR) are filed with the Financial Intelligence Unit (FIU) when appropriate. The AML Compliance Person is vested with full responsibility and authority to enforce the firm’s AML program. The Company has provided the Authorities with contact information for the AML Compliance Person, including: (1) name; (2) title; (3) mailing address; (4) email address; (5) telephone number; and (6) facsimile number. The Company will promptly notify the Authority of any change in this information and will review, and if necessary update, this information within 14 business days after the end of each calendar year. The annual review of FCS information will be conducted by CO and will be completed with all necessary updates being provided no later than 17 business days following the end of each calendar year. In addition, if there is any change to the information, CO will update the information promptly, but in any event not later than 30 days following the change.


365 Emoney ® Preventive Measures. This section underlines that “Countries should ensure that Money Laundering and Terrorism (Prevention) Act do not inhibit implementation of the FATF Recommendations. Financial institutions should be prohibited from keeping anonymous accounts or accounts in obviously fictitious names.


Financial institutions should be required to undertake customer due diligence (CDD) measures when: 
 (i) establishing business relations;

 (ii) carrying out occasional transactions (i) above the applicable designated threshold (USD/EUR 15,000); 
 or (ii) that are wire transfers in the circumstances covered by the Interpretive Note to Recommendation 16; 

(iii) there is a suspicion of money laundering or terrorist financing;
or (iv) the financial institution has doubts about the veracity or adequacy of previously obtained customer identification data. The principle that financial institutions should conduct CDD should be set out in law. Each country may determine how it imposes specific CDD obligations, either through law or enforceable means. The CDD measures to be taken are as follows:

(a) Identifying the customer and verifying that customer’s identity using reliable, independent source documents, data or information.

(b) Identifying the beneficial owner, and taking reasonable measures to verify the identity of the beneficial owner, such that the financial institution is satisfied that it knows who the beneficial owner is. For legal persons and arrangements this should include financial institutions understanding the ownership and control structure of the customer. 

(c) Understanding and, as appropriate, obtaining information on the purpose and intended nature of the business relationship.

(d) Conducting ongoing due diligence on the business relationship and scrutiny of transactions undertaken throughout the course of that relationship to ensure that the transactions being conducted are consistent with the institution’s knowledge of the customer, their business and risk profile, including, where necessary, the source of funds.

(i) Above the applicable designated threshold (USD/EUR 15,000); or (ii) that are wire transfers in the circumstances covered by the Interpretive Note to Recommendation 16; 

(iii) There is a suspicion of money laundering or terrorist financing; or (iv) the financial institution has doubts about the veracity or adequacy of previously obtained customer identification data. The principle that financial institutions should conduct CDD should be set out in law. Each country may determine how it imposes specific CDD obligations, either through law or enforceable means. 

The CDD measures to be taken are as follows:

 (a) Identifying the customer and verifying that customer’s identity using reliable, independent source documents, data or information. 

(b) Identifying the beneficial owner, and taking reasonable measures to verify the identity of the beneficial owner, such that the financial institution is satisfied that it knows who the beneficial owner is. For legal persons and arrangements this should include financial institutions understanding the ownership Financial institutions should be required to apply each of the CDD measures under (a) to (d) above, but should determine the extent of such measures using a risk-based approach (RBA) in accordance with the Interpretive Notes to this Recommendation and to Recommendation 1. Financial institutions should be required to verify the identity of the customer and beneficial owner before or during the course of establishing a business relationship or conducting transactions for occasional customers. Countries may permit financial institutions to complete the verification as soon as reasonably practicable following the establishment of the relationship, where the money laundering and terrorist financing risks are effectively managed and where this is essential not to interrupt the normal conduct of business.


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