AML&KYC

Introduction

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy is designed to mitigate the risks associated with money laundering and other unlawful activities. This summary outlines the key aspects of the policy but does not cover all details. To access the full document, please contact customer support.
AV DIGITAL SOLUTIONS is required to comply with both domestic and international regulations to prevent money laundering, terrorist financing, drug and human trafficking, the proliferation of weapons of mass destruction, corruption, and bribery. Additionally, AV DIGITAL SOLUTIONS must take appropriate measures to identify and address any suspicious activity involving its customers.

Anti-Money Laundering Compliance Officer

The AMLCO oversees compliance with AML regulations. While the terms "compliance officer" and "AMLCO" may refer to the same person, their specific duties may differ.
The AMLCO has the necessary authority and full access to relevant information to fulfill their responsibilities effectively.

General Principles

Verify customer identities, maintain transaction records, monitor and detect unusual or suspicious transactions, and implement internal reporting and control measures as needed.
Ensure that employees understand their AML responsibilities and are well-versed in the company’s AML procedures.
Provide relevant staff with adequate training on AML compliance.
Direct any external AML-related requests to the designated Anti-Money Laundering Compliance Officer (AMLCO).

Identity Check

When verifying a new customer’s identity, the company must ensure that all provided documentation sufficiently confirms the customer’s identity and legal existence. While third-party services may assist in this verification process, the company remains fully responsible for ensuring compliance with required standards.
The collection, storage, sharing, and protection of customer identity data will be managed in accordance with the company’s Privacy Policy and the General Data Protection Regulation (GDPR).

Transaction Monitoring

Continuous monitoring of customer accounts and transactions is essential in mitigating the risks of money laundering and terrorist financing. The AMLCO is responsible for developing and improving these monitoring processes within the company.

Sanctions Compliance

AV DIGITAL SOLUTIONS Sp. z.o.o. strictly adheres to international sanctions and does not engage in transactions with individuals, businesses, or countries subject to sanctions imposed by authorities such as the United Nations and the European Union. These sanctions help prevent dealings with entities involved in illegal activities or threats to global security.
To ensure compliance, the company screens customers, business partners, and transactions against sanction lists. Any violations will lead to the immediate suspension of the transaction and reporting to the appropriate regulatory bodies.

Risk Assessment

AV DIGITAL SOLUTIONS follows a risk-based approach to concentrate its AML efforts where the risk of money laundering and terrorist financing is highest. The AMLCO continually evaluates the effectiveness of these procedures.
This risk-based strategy includes:

Recognizing that AML risks vary based on customer profiles, geographic locations, services, and financial instruments.
Allowing the board of directors to classify customers according to their specific risk levels.
Enhancing efficiency in AML compliance.
Prioritizing actions based on the likelihood of money laundering or terrorist financing.
Customizing AML policies, procedures, and controls to fit the company’s unique operational environment.

Restricted Regions

In accordance with international regulations, the company restricts its services in certain high-risk jurisdictions. These countries are identified based on global AML risk assessments.
A complete list of restricted countries is available in the full AML policy, which can be requested from the company. The list is regularly updated, and any changes take effect immediately upon policy revisions.
By limiting services in these high-risk regions, the company strengthens its compliance efforts and reinforces its commitment to operational integrity.