AML Policy
The Director of EASY SUCCESS LTD (the “Company”) approved this policy on 15/01/23.
This guideline gives a basic overview of the KYC & AML Policy standards followed by the Company on the website of the Company when working with individuals, legal entities/individual entrepreneurs (hence the Contractor).
This document demonstrates the Company’s preventing money laundering and terrorist funding in its business practices and transactions. Money laundering is the process of concealing the unlawful origin of financial profits from crime. Terrorist financing refers to any type of financial assistance provided to those who try to encourage, plot, or participate in terrorism.
To prevent money laundering and terrorism financing, the company has implemented KYC rules. These processes allow us to identify every organisation with which we do business, evaluate the legitimacy of our business relationships, and discover and react to suspicious behaviour.
APPLICATION OF THIS KYC & AML POLICY
This KYC & AML Policy pertains to all people, including those who work solely on a volunteer basis with the Company. The Company will end its engagement with any individual who violates this KYC & AML Policy.
CONTRACTOR ACCEPTANCE POLICY
The following are the objectives of the client acceptance policy:
- to ensure that no account is created with a fake name;
- to confirm the contractor’s residence/legal location;
- to verify the contractor’s identification;
- to ensure that the contractor is not engaged in any suspect activity.
CONTRACTOR IDENTIFICATION
The following information must be gathered and verified:
- first and last name;
- date of birth;
- location.
The following papers must be provided by the contractor:
- proof of identification (passport, driving license);
- proof of location (telephone) ;
- Bill / Bank Account Balance;
- letter from any known governmental body;
- utility bill;
- employer letter.
TRANSACTIONS MONITORING
A successful KYC procedure involves ongoing monitoring. The main duty of the Company is to oversee contractor payouts. The Company understands the customer’s typical and reasonable activity to spot deals that deviate from the regular activity.
- Screening of contractor
The Company searches all pertinent sanctions lists for the contractor’s name to find sanctioned people or organisations.
- Transactions screening
The Company performs real-time screening of all parties engaged in the transaction/payment against all pertinent financial sanctions watch lists.
SANCTIONED COUNTRIES
Afghanistan, American Samoa, Angola, Bahamas, Botswana, Belarus, Burundi, Cambodia, Central African Republic, Chad, Congo, Cuba, Democratic Republic of Congo, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guam, Guinea Bissau, Iran, Iraq, North Korea, Lebanon, Libya, Mali, Nigeria, Pakistan, Panama, Puerto Rico, Russia, Samoa, Saudi Arabia, Sierra Leone, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Venezuela, Yemen, Zimbabwe, some states of USA.
The necessity for effective sanctions list administration, as well as dependable sanctions screening tools, is crucial. Keep in mind that sanctions lists are continuously watched and revised. The aforementioned countries are sanctioned by default.
SUSPICIOUS ACTIVITY REPORTS
Among the suspect actions are the following:
- The contractor exhibits unusual concern for secrecy, especially concerning his/her name or past, or declines to provide the requested documents;
- The contractor provides unusual or suspicious identification documents that cannot be verified;
- The contractor uses the website to perform money transmission, exchange, and/or cash-out operations;
- The contractor, for no apparent reason, opens multiple accounts under a single name or uses multiple names for the same person to open accounts;
- The contractor or an individual affiliated with Contractor has a questionable background (including previous criminal convictions) or is the topic of press reports suggesting potential criminal, civil, or regulatory violations.
When an individual reports a suspicion about a potential or actual contractor (or related transaction) to the Company following the procedure described in this KYC & AML Policy, the individual has fully satisfied their statutory obligation to report such suspicions.
If any individual becomes aware of any information or other matter that leads to knowledge or suspicion that another person is involved in suspicious activities, or if the individual has an unresolved concern about any unusual circumstance, the individual must discuss it with the Company as soon as possible.
Date of effect: 15/01/2023