Anti-money Laundring (AML) policy

1. Purpose and Scope

Valvest.io is committed to the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. The purpose of this AML policy is to protect Valvest.io from being used for money laundering or terrorist financing activities, to protect our reputation, and to comply with applicable AML laws and regulations, including those set by the Financial Action Task Force (FATF), European Union directives, and other relevant local and international regulations.

This policy applies to all employees, contractors, consultants, and third parties who engage with Valvest.io in any business capacity.

2. Definitions

3. User Registration Requirements

Valvest.io is fully committed to:

• Preventing its platform from being used for money laundering and terrorist financing activities.
• Complying with all applicable AML regulations and industry best practices.
• Implementing robust internal controls and procedures to detect, prevent, and report suspicious activities.
• Conducting regular training sessions to educate employees about their roles and responsibilities under AML laws.

4. Risk-Based Approach

Valvest.io adopts a risk-based approach to AML compliance, which involves:

• 1. Identifying and Assessing Risks: Conducting comprehensive risk assessments to identify potential risks related to customers, products, services, transactions, and geographic locations.
• 2.Mitigating Risks: Implementing appropriate measures and controls to mitigate identified risks, including enhanced due diligence for higher-risk customers and transactions.
• 3.Ongoing Risk Review: Regularly reviewing and updating the risk assessment process to reflect changes in business operations, customer base, or regulatory environment.

5. Customer Due Diligence (CDD) Procedures

To comply with CDD requirements, Valvest.io will:

• 1. Customer Identification and Verification: Collect and verify identification information for all customers before establishing a business relationship. Acceptable identification documents include a valid passport, national ID card, or driver’s license. For corporate entities, relevant business registration documents, proof of address, and information about beneficial owners will be required.
• 2. Risk Profiling: Assign risk ratings to customers based on various factors, including country of residence, type of business, transaction volume, and known political exposure.
• 3.Ongoing Monitoring: Continuously monitor customer transactions to detect unusual patterns or behavior that may indicate money laundering. Implement transaction thresholds and alerts to flag suspicious activities.
• 4. Enhanced Due Diligence (EDD): Apply EDD measures to high-risk customers, such as those with complex ownership structures, PEPs, or customers from high-risk jurisdictions. EDD may involve obtaining additional information on the customer’s source of funds, purpose of transactions, and ongoing business activities.

6. Reporting Suspicious Activities

• 1.Internal Reporting:Employees must report any suspicious activities or transactions to the AML Compliance Officer immediately. Suspicious activities may include large, unusual, or unexplained transactions, inconsistent information provided by customers, or attempts to avoid reporting requirements.
• 2.Investigation and Documentation: The AML Compliance Officer will investigate reported suspicious activities, document findings, and determine if a Suspicious Activity Report (SAR) should be filed.
• 3.External Reporting: If required, SARs will be filed with relevant regulatory authorities promptly. Valvest.io will cooperate fully with law enforcement agencies in their investigations.

7. Record keeping

Valvest.io will maintain comprehensive records to comply with legal and regulatory requirements. Record-keeping includes:

• 1. Customer Identification Records: Copies of identification documents and verification data will be retained for at least five years after the end of the business relationship.
• 2. Transaction Records: Detailed records of all customer transactions, including transaction amounts, dates, and parties involved, will be maintained for a minimum of five years.
• 3. Suspicious Activity Reports (SARs): Records of SARs and internal investigations will be securely stored for at least five years after the report is made.

8. Employee Training and Awareness

Valvest.io will provide regular AML training to all employees to ensure they understand:

• 1. AML Regulations and Obligations: The importance of AML compliance, relevant regulations, and the consequences of non-compliance.
• 2. Recognizing Suspicious Activities: How to identify red flags and indicators of money laundering or terrorist financing.
• 3. Reporting Procedures: The process for reporting suspicious activities to the AML Compliance Officer.

Training sessions will be conducted annually, with additional sessions provided as needed based on regulatory updates or changes in company procedures. Training records will be maintained for all employees.

9. Technology and Systems

Valvest.io will utilize advanced technology solutions to enhance AML compliance efforts, including:

• 1. Transaction Monitoring Systems: Automated systems to monitor transactions in real-time, identifying unusual patterns and flagging suspicious activities.
• 2. Sanctions and PEP Screening: Screening tools to check customer names against international sanctions lists, PEP lists, and other high-risk databases.
• 3. Data Analytics: Use of data analytics to identify trends and anomalies that may indicate money laundering.

10. Compliance Monitoring and Internal Audit

• 1. Ongoing Compliance Monitoring: The AML Compliance Officer will oversee the implementation and effectiveness of AML policies and procedures. Regular reviews will be conducted to ensure compliance with regulatory requirements.
• 2. Internal Audit: Periodic internal audits will be conducted to assess the effectiveness of the AML program, identify areas for improvement, and ensure adherence to policies. Audit results will be reported to senior management, and corrective actions will be implemented promptly.

11. Reporting Obligations

Valvest.io will comply with all regulatory reporting obligations, including:

• 1. Currency Transaction Reports (CTR): Reporting large cash transactions that exceed regulatory thresholds to relevant authorities.
• 2. Suspicious Activity Reports (SAR): Filing SARs for transactions or activities that are deemed suspicious, even if the exact nature of the suspicious activity is not known.

12. Penalties for Non-Compliance

Failure to comply with this AML policy can result in disciplinary actions against employees, which may include termination of employment. Valvest.io may also face significant legal and financial penalties, including fines and sanctions, for non-compliance with AML regulations.

13. Confidentiality and Data Protection

• 1. Confidentiality: All information related to customer identification, transactions, and suspicious activities will be treated as confidential. Access to such information will be restricted to authorized personnel only.
• 2. Data Protection: Valvest.io will ensure that all customer data and records are protected by robust data security measures in compliance with data protection laws.

14. Policy Review and Updates

This AML policy will be reviewed at least annually or more frequently if required by changes in regulations or business operations. Any updates or changes to the policy will be communicated to all employees and relevant stakeholders.

15. Contact Information

For any questions or further information about this AML policy, please contact the AML Compliance Officer at joep@valvest.io.