Anti Money Laundering Policy

Our Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of NEROTAN being involved in any kind of illegal activity.

Both international and local regulations require NEROTAN to implement effective internal procedures and mechanisms to prevent Money laundering, Terrorism financing, Narcotics and Human trafficking, Proliferation of weapons, Corruption and Bribery; and to take action in case of any form of suspicious activity from its Users.

Our AML/KYC Policy covers the following matters:

1. Verification procedures.

2. Compliance Officer.

3. Monitoring Transactions.

4. Risk Assessment.

 

Verification procedures

One of the international standards for preventing illegal activity is customer due diligence (“CDD”). Consequently, NEROTAN establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.

 

Identity verification

NEROTAN's identity verification procedure might requires the user to provide us with reliable, independent source documents, data or information (e.g., National ID, International passport, Voter's Card, Bank statement, Utility bill). For such purposes, NEROTAN reserves the right to collect users’ identification information for the AML/KYC Policy purposes.

NEROTAN will take steps to confirm the authenticity of documents and information provided by the users. All legal methods for double-checking identification information will be used and NEROTAN reserves the right to investigate certain users who have been determined to be risky or suspicious.

NEROTAN reserves the right to verify users' identity on an on-going basis, especially when their identification information has been changed or their activity seems to be suspicious (unusual for the particular user). In addition, NEROTAN reserves the right to request up-to-date documents from the users, irrespective of if they previously fulfilled identity verification requirements.

Users' identification information will be collected, stored, shared and protected strictly in accordance with NEROTAN's Privacy Policy and similar regulations.

Once the user’s identity has been verified, NEROTAN is able to absolve itself of potential legal liability in a situation where its Services are used to conduct illegal activity.

 

Compliance Officer

The Compliance Officer is the person, duly authorized by NEROTAN with the duty of ensuring the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of NEROTAN'S anti-money laundering and counter-terrorist financing, including but not limited to:

  1. Collecting Users’ identification information. 
  2. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations. 
  3. Monitoring transactions and investigating any significant deviations from normal activity. d. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs. 
  4. Updating risk assessment regularly. 
  5. Providing law enforcement with information as required under the applicable laws and regulations.

 

The Compliance Officer is entitled to interact with law enforcement, which is involved in the prevention of money laundering, terrorist financing and other illegal activity.

 

Monitoring Transactions

Users are known not only by verifying their identity but also by analyzing their transactional patterns (what they do). Therefore, NEROTAN relies on data analysis as a risk-assessment and suspicion detection tool. NEROTAN performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management and reporting. 


Risk Assessment

NEROTAN, in line with the global requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, NEROTAN is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention 


Last Updated September, 2020


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