ANTI-MONEY LAUNDERING POLICY
Money laundering is the act
of converting money or other monetary instruments gained from illegal activity
into money or investments that appear to be legitimate so that its illegal
source cannot be traced. It is known that persons involved in Money
laundering use forged documents of identification and false information for the
purpose of money laundering activities through banking institutions. Thus, the
main principle that underlies all other actions related to prevention of Money
laundering and financing of terrorism is establishment of the identity of
System customers and carrying out the «Know Your Customer» procedures.
IMPLEMENTED PROCEDURES
The objective of anti-money
laundering procedures that Intel Express System implements is to ensure that
customers engaging in certain activities are identified to a reasonable
standard, while minimizing the compliance burden and impact on legitimate
customers.
Other
guiding principles of the system created for the purposes of anti-money
laundering and financing of terrorism are:
- Mitigation of risks of the
System being used as an intermediary in Money laundering and financing of
terrorism operations;
- Protection of the System from
goodwill and financial losses arising in connection with attempts to use
the System for the purposes of operations connected with Money laundering
and financing of terrorism;
- Detection of operations subject
to obligatory control and detection of suspicious operations, registration
of such operations and maintain detailed records of
all transactions, and report such activities providing timely and
comprehensive advice to law enforcement;
- Ensuring of continuous
compliance with set anti-money laundering and financing of terrorism
requirements monitoring;
- Intel Express staff
participation in the realization of internal control programs for the
purposes of anti-money laundering and financing of terrorism;
- Observance of confidentiality
status of the information obtained in the process of activities.
Intel Express System is
committed to assisting governments combat the threat from money laundering and
terrorist financing activities around the world. For that purpose Intel Express
System has setup a highly sophisticated electronic system.
OUR COMPLIANCE REGIME
IntelExpress System implemented a compliance regime, as
laws require from financial institutions, including appointment of a compliance
officer, preparation of policies and procedures, periodic review of their
effectiveness, and ongoing compliance training of our staff.
The System is connected to the network of the Office of Foreign
Assets Control ("OFAC") of the US Department of the Treasury, uses its database and software “OFAC Data Download“. The database contains a Permanently Updated List of
terrorists, drug traffickers and other Specially Designated physical persons
and legal entities.
Software of Intel Express identifies data of all persons involved in money
transfer (both of the receiver and the sender) as well as in other financial
transactions are verified online with data of the Permanently Updated List of
terrorists, drug traffickers and other Specially Designated physical persons
and legal entities published by the Office of Foreign
Assets Control. Partial as well as full
verification of identification data is carried out.
