Vedova Limited AML Policy


This procedure establishes the order of realizing the requirements of law regulations, which regulate money laundering and terrorist financing prevention in Vedova Limited (hereafter company, Vedova, Vedova Limited). It is applicable to the company, which deals with the release and buyout of electronic money, provides with the services of payment, issues the measures of payment and engages in other activities, requiring the security of the prevention of the money laundering and terrorist financing.
This procedure was prepared according to the requirements of money laundering and terrorist financing prevention law (hereafter Law) of the United Kingdom and the directive 2005/60/EC of 26 October 2005 of the European Parliament and Council on the prevention of the use of financial system for the purpose of money laundering and terrorist financing and the requirements of the regulation (EC) 1781/2006 (hereafter Regulation (EC) 1781/2006) of 15 November 2006 of the European Parliament and Council on the payer's information, given while transferring the funds (OL 2006 L 345, p. 1).
The definitions used in this procedure are perceived in the way they are defined in Law.

RISK ASSESSMENT OF MONEY LAUNDERING AND/OR TERRORIST FINANCING

1. The risk of money laundering and terrorist finance in the company is assessed by distinguishing such kinds of risks as the risk of the customer, products and/or services, country and/or geographical region, opening of a virtual account.
2. In order to assess the risk of money laundering and/or terrorist financing in a company, the professional competence and procedure is followed.
3. Deficient or incomplete information about the customer is considered as a criterion by the company when assessing whether the transfer of money or any other related transaction is suspicious and needed to be reported to the corresponding institutions.

IDENTIFICATION OF CUSTOMER AND BENEFICIARY

1. Employees of the company must determine whether the customer and the beneficiary operates on their own, or are being in control, also identify and verify their identities.
2. In order to ensure a comprehensive prevention, while examining and defining the identity of the customer and beneficiary, the company must:
  • obtain the information from the customer about the purpose and the intended nature of business relationship;
  • get the identification documents of the customer, containing the information about the beneficiary and the customer himself;
  • rely on documents, data or information obtained from a reliable and independent source: the information provided by the bank of the customer, official documents, which contain personal photography and / or the corresponding registration number, are unable to be easily copied or forged (passport, identity card, driving license, a legal entity registration certificate, notarized copies of documents, etc.), which indicate the name of the customer, surname, personal identification number or another unique sequence of numbers for the identification of a person, a personal picture and (or) the signature, etc. (for a natural person), or the name, address, code, registration certificate number, VAT number, etc. (for a legal person); publicly available information by databases; by the recommendations of the other credit institutions, etc.;obtain such information that it would be possible to understand the management system of the customer (legal person) and the nature of business.
3. Verifying the identity of the customers, the attention is paid whether the customer is not entered in the list of consolidated individuals, their groups and companies with institutions, which carry the financial penalties of European Union (renewed consolidated list is given in the official website of the European Commission: http:// eeas.europa.eu/cfsp/sanctions/consol-list_en.htm).
4. It is prohibited for the employees of the company to run the monetary operations if the customer does not provide the documents verifying his identity, provides incomplete or false data, which is known for the employees of the company, avoids providing information, necessary for identification, conceals beneficiary identification, avoids providing or does not provide information, needed for beneficiary identification, or the provided data is insufficient.

5. During customer identification (natural person), there are some documents, required from him, which contain the data of his identity:
  • name (names);
  • surname (surnames);
  • personal number (applicable for the citizens of the United Kingdom);
  • date of birth, personal number or another unique sequence of numbers for the identification of the person (applicable for foreigners).
6. Regarding the method based on the risk assessment, these means of identification are applied:
  • Simplified identification of the customer. When there is only a request for the document verifying the identity.
  • Consolidated identification of the customer. When there is a request for other sources or institutions to verify or provide information about the person's identity or the person himself.
7. When the monetary operation is run and the transaction is made with a representative, the requested data about both the principal and the representative must be established; requirements, set for customer identification, are equally applicable for the customers who directly approach the company as much as for those whose diplomatic relations, monetary operations and transactions are run with the representative, or the customer is physically absent during the process of his identification.
8. In case of disapproval from the customer to verify the identity by the indicated means or causing suspicions due to performed actions, the company can report this issue to the corresponding institutions.

9. Obligations to the customers of Vedova Limited:
a) By using Vedova Limited services, I confirm that me or close family members* or close associates** are not politically exposed natural persons. Otherwise I will inform Vedova Limited about this situation by written notice to e-mail compliance@vedova.ltd.uk.

*Close family members mean the spouse, the person with whom partnership has been registered (hereinafter referred to as cohabitant), the parents, brothers, sisters, grandparents, grandchildren, children and children's spouses, children's cohabitants.

**Close associate means a natural person who, together with the person who is or has been participating in the same legal person or maintains other business relations.

b) By using Vedova Limited services I hereby confirm that I am the actual owner (beneficiary) of funds.

c) By using Vedova Limited services I hereby confirm that I undertake all operations on my behalf and I am not authorized by any other person to undertake operations on his/her/its behalf. Otherwise I will inform Vedova Limited about this situation by written notice to e-mail compliance@vedova.ltd.uk.