Invictus Solution ANTI-MONEY LAUNDERING, KNOW YOUR CUSTOMER AND COMBATING TERRORISM POLICY
In order to counter the penetration of criminal capital into the state’s economy and withstand the spread of crime, most of countries implement relevant measures to prevent money laundering and terrorist financing. Invictus Solution has implemented all required due diligence measures to identify and mitigate possible risk of Invictus Solution being involved in illegal activity. By doing so, Invictus Solution maintains a strong principled stance on the prevention of all illegal activities as well as following related regulations.
Aiming to fulfil these obligations, Invictus Solution is obliged to inform corresponding Official Authorities on Customer’s suspicious activity, if there is reasonable ground to suspect that appropriate funds are related to money laundering and/or terrorist financing. Invictus Solution is required to block such funds and take other measures based on internal AML policy and relevant Law.
Money laundering (ML) means:
• withholding or non-disclosure of information on true origin, source, location, transfer, ownership or other rights to property/assets/funds obtained in result of illegal activity (or property/assets received in exchange for such property/assets);
• converting, transferring, receiving, possessing or using of property obtained through criminal activity (or property received in exchange for such property) in order to conceal the illicit origin of such property or to assist individuals involved in criminal activity to avoid the legal consequences of their actions;
• the situation in which property/assets/funds was (were) obtained as result of criminal activity committed in the territory of another State.
Terrorist Financing (TF) means:
• collection or provision of funds with the intention that they may be used to support terrorist acts or organizations.
Risk assessment
Invictus Solution adopts a risk-based approach to customer due diligence («CDD») and ongoing monitoring. For this approach, where the ML/TF risks related to customers are considered to be higher, the company will take enhanced measures to manage and mitigate those risks.
Risk assessments form the basis of the Invictus Solution risk-based approach. The company performs risks assessments at both the institutional level and at the customer level to understand how, and to what extent, it is vulnerable to ML/TF risks.
For customer level risk assessments, the Invictus Solution shall take appropriate steps to identify, assess and understand its money laundering and terrorism financing risks in relation to:
d) its customers;
a) the countries or jurisdictions its customers are from or in;
b) the countries or jurisdictions it has operations in; and
c) its products, services, transactions and delivery channels.
The company applies a weighted AML customer risk scoring model to assess the prospective and existing customer taking into account all information and insight gained during the due diligence process. The risk score will then drive the periodic review and any enhanced monitoring requirements of the customer. Invictus Solution has the assigned Compliance officer who is responsible for implementation of Invictus Solution AML policy.
Cooperating with Invictus Solution, the Customer accept the following obligations:
• guarantees that he/she will comply with all laws and regulations on combating money laundering and terrorist financing;
• confirms that he/she has no information or suspicions that funds/crypto assets loaded on the account in the past, present or future are obtained from an illegal source or have any relation to illegally obtained income legalization or other illegal activities, prohibited by the current legislation, Institutions, and International Organizations;
• agrees immediately provide Invictus Solution with any information requested in order to comply with applicable laws and anti-money laundering requirements;
Invictus Solution retain the right to transfer the information it holds, including personal data and transaction history, to relevant authorities, for the purpose of fraud and money laundering cases investigation.
Invictus Solution uses certified thirst party provider identification documents to collect and store relevant identification documents, monitors suspicious activities, and keeps records of all transactions made on the account.
Invictus Solution reserves the right at any time and at any stage to cancel transaction/operation, in case Invictus Solution has reason to believe the transaction/operation has relation to money laundering, terrorist financing and/or criminal activity.
According to AML Regulations and International law, Invictus Solution is not obliged to notify the customer that his/her activity is suspicious and this information has been transferred to the relevant government authorities.
According to the internal AML Policy, Invictus Solution conducts initial and ongoing CDD (customer due diligence) process based on customer’s risk level assessment. As part of this process, Invictus Solution will carry out the following actions, being a part of CDD process:
• require the provision of minimum data to verify the identity of the customer.
• record and store data and documents (with the use of third-party provider) proving the identity of the user, as well as information about which methods were used to verify the identity, and the results of checks.
• check the personal data of clients for matches with PEP and Sanctions lists as well as the list of persons suspected of terrorism, formed by authorized state and independent bodies. The minimum set of user identification data includes: full name, date of birth, residential address.
• request the source/origin of funds the user plans to deposit into the account.
To verify and confirm the data authenticity, Invictus Solution may require the Customer to pass KYC (know your customer) procedure and provide the following documents:
• passport, or identification card, or any other document replacing them that meets the following requirements: contains the name, date of birth and photograph of the owner of the document and was issued by national government authorities;
• a recently received utility bill (not older than 3 months) or other document confirming the user’s residential address;
Invictus Solution may also request any other additional information, supported by appropriate documentation. In certain cases, Invictus Solution may also request notarized copies of documents from Customer.