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AML/CTF policy ADVDigital Union EOOD

1. Policy Statement

ADVDigital Union EOOD is committed to fully comply with all applicable laws and regulations regarding anti-money laundering procedures. ADVDigital Union EOOD has adopted and will enforce the provisions set forth in AML/CFT Regulations in order to prevent and detect money laundering, terrorist financing and other illegal activities. If ADVDigital Union EOOD, its personnel and/or premises are inadvertently used for money laundering or other illegal activities, ADVDigital Union EOOD can be subject to potentially serious civil and/or criminal penalties. Therefore, it is imperative that every member, officer, director, and employee (each, an "Employee") is familiar with and complies with the policy and procedures set forth in this document. This Compliance Statement is designed to assist all clients in adhering to ADVDigital Union EOOD policy and procedures, which, if followed diligently, are designed to protect themselves, ADVDigital Union EOOD, its Employees, its facilities and its activities from money laundering or other illegal activities. To ensure that the ADVDigital Union EOOD policies and procedures are adhered to, ADVDigital Union EOOD shall designate an Anti-Money Laundering Compliance Officer (the "Compliance Officer"). The Compliance Officer is responsible for establishing and conducting Employee training programs to ensure that all appropriate Employees are aware of the applicable AML/CFT Laws and Regulations, ADVDigital Union EOOD AML/CFT Policies & procedures and their responsibilities with respect to these policies.

2. Objectives of ADVDigital Union EOOD Anti-Money Laundering / Counter Financing of Terrorism Policy and Procedures

3. What is Money Laundering?

Money laundering involves the placement of illegally obtained money into legitimate financial systems so that monetary proceeds derived from criminal activities are transformed into funds with an apparently legal source. Money laundering has many destructive consequences both for society as a whole and for those entities involved in money laundering activities. With respect to society as whole, money laundering may provide resources for drug dealers, terrorists and other criminals to operate and expand their criminal activities. With respect to entities, any involvement whether it be to instigate, assist, conceal, or ignore the source, nature, location, ownership or control of money laundering activities, can lead to both civil and criminal proceedings against both the individual and the entity involved . Additionally, the adverse effects, including the adverse publicity to the Firm associated with involvement in money laundering events cannot be emphasized enough.

Money laundering transactions may include:  

Money laundering can involve the proceeds of drug dealings, terrorist activities, arms dealings, mail fraud, bank fraud, wire fraud or securities fraud, among other activities.

4. What Is Terrorist Financing?

Terrorist financing refers to the processing of funds to sponsors involved in or those who facilitate terrorist activity. Terrorist individuals/ groups/ organization derive income from a variety of sources, often combining both lawful and unlawful funding, and where the agents involved do not always know the illegitimate end of that income. The forms of such financing can be grouped into two types:

Financial Support – In the form of donations, community solicitation and other fundraising initiatives. Financial support may come from states and large organizations, or from individuals.

Revenue Generating Activities - Income is often derived from criminal activities such as kidnapping, extortion, smuggling or fraud. Income may also be derived from legitimate economic activities such as diamond trading or real estate investment

5. Anti-Money Laundering Compliance Officer

The ADVDigital Union EOOD has appointed a dedicated Compliance Officer to oversight the Compliance function who will be reporting to the Board of Directors of the ADVDigital Union EOOD. Any Employee shall immediately notify the Compliance Officer if he/she suspects or has any reason to suspect that any potentially suspicious activity has occurred or will occur if a transaction is completed. Employees are encouraged to seek the assistance of the Compliance Officer with any questions or concerns they may have with respect to the ADVDigital Union EOOD AML/CFT Policy & Procedures.

Responsibilities of the Compliance Officer include the following:

6. Anti-Money Laundering Employee Training Program

As part of the ADVDigital Union EOOD anti-money laundering program, all Employees are expected to be fully aware of the ADVDigital Union EOOD AML/CFT policy and procedures. Each Employee is required to read and comply with this Compliance policy and procedures, address concerns to the Compliance Officer and sign the acknowledgement form confirming that he/she has read and understands ADVDigital Union EOOD AML/CFT policy and procedures. To ensure the continued adherence to ADVDigital Union EOOD AML/CFT policy and procedures, all Employees are required to reconfirm their awareness of the contents of this document by signing the acknowledgement form annually, or more frequently, as required by the Compliance Officer.

All Employees are required;  

7. Client Identification Procedures

1. General

ADVDigital Union EOOD AML/CFT policy and procedures are intended to ensure that, prior to accepting funds from Clients, all reasonable and practical measures are taken to confirm the Clients' identities.

ADVDigital Union EOOD may take assistance from the bank or other financial institutions for completing client identification process. The assistance shall not relieve the ADVDigital Union EOOD for identification process to be conducted by the company.

These Client Identification Procedures are based on the premise that the ADVDigital Union EOOD will accept funds from a new and existing Client only after:

The Client Identification Procedures should be reviewed in light of the specific characteristics presented by a Client and in any instance the Compliance Officer may determine to apply enhanced measures for reasons other than those discussed in section below.

As a reference tool, an Individual Client KYC Checklist is used. Employees are encouraged to provide the Compliance Officer with any revisions they consider appropriate. The Compliance Officer shall retain copies of all documents reviewed or checklists completed in connection with its Client Identification Procedures in accordance with ADVDigital Union EOOD Client Records Retention policy.

Every Customer shall be identified for establishing business relationship. For this purpose, investors need to fill out the Account Opening Form available at the customer support counters at ADVDigital Union EOOD office or download it from ADVDigital Union EOOD website.

2. Client Identification Procedures for Natural Persons

For Identity and due diligence purposes, at the minimum following information shall be obtained, verified and recorded on KYC/CDD form or account opening form:

Joint Accounts: In case of Joint account, the customer due diligence measures on all of the joint account holders shall be performed as if each of them were individual customers of the ADVDigital Union EOOD.

3. Client Identification Procedures for Corporations, Partnerships, Trusts and Other Legal Entities

ADVDigital Union EOOD shall take reasonable steps to ascertain satisfactory evidence of an entity Client's name and address.

For Identity and due diligence purposes, at the minimum following information shall be obtained, verified and recorded on KYC/CDD form:

4. Customers’ Screening

In terms of AML/CFT Regulations, it is prohibited to provide services to proscribed individual & entities or to those who are known for their association with such individuals & entities, whether under the proscribed name or with a different name. Accordingly, it is imperative for ADVDigital Union EOOD to monitor its relationships on a continuous basis and ensure that no such relationship exists. Further, in case, if any such relationship is found, immediately report the same to Financial Monitoring Unit (FMU) and take any other action, as per law.

In pursuance of above, all customers should be prorely screened through UN/OFAC sanctioned lists as available in the data base of the company.

5. Approval

The account will only be processed for account opening after it has been authorized by Compliance officer and incase of High risk customer, by the senior management of ADVDigital Union EOOD.

6. Account Shall Not Open

8. General Reporting Procedures

9. Policy Review Period

The AML/CFT Policy & Procedures will be reviewed on as and when required basis but not

later than two years.