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AML POLICY
1. Customer acceptance policy This policy follows the general principles, laws, regulations and guidelines intended to prevent money laundering. The company is implementing security measures and has adopted policies, practices and procedures that promote high ethical and professional standards. This ensures that the company is not used, whether intentionally or accidental, by individuals involved in criminal activities.
To support this commitment, the company has established Know Your Customer (KYC) procedures. as an essential component of its services, risk management strategies and control mechanisms. These procedures include: Client risk assessment. Verification and authentication of Clients. Constant monitoring of high-risk accounts and transactions. Risk management.
The company not only has the responsibility of authenticating the identity of its Clients, but also to monitor activity on accounts to identify any unusual transactions or behavior that is not consistent with the typical history of that Customer or type of account. The process of "Know Your Customer" (KYC) occupies a central place in our management and control procedures of risks in services, and the intensity of these procedures is adjusted depending on the level of risk.
The company implements highly transparent policies and procedures for the entry of Clients, that detail the types of Clients that could represent a higher risk than anticipated. Before accepting a potential Client, Know Your Customer (KYC) processes are applied and due diligence, with evaluation of the following aspects: Client History. Nationality. Public position or notoriety (for example, PEPs). Age of the Client (must be over 18 years old). Relationship with other accounts. Commercial operations. Any other factor indicative of risk.
Enhanced due diligence is implemented for individuals originating from identified countries as high risk, as well as for Politically Exposed Persons (PEPs), financial structures complex and high-net-worth clients whose source of funds is unclear. The funds of the New Clients are channeled through banking institutions with a solid reputation, which follow their own rigorous anti-money laundering procedures. The decision to establish Commercial relationships with higher risk Clients, such as PEPs, are taken exclusively at the senior management level.
The company's operating procedures regarding the inclusion of new merchants, Compliance requirements, as well as deposit and withdrawal processes, are detailed as follows: The Compliance department is responsible for verifying the documentation provided by Clients with the in order to identify and verify the information delivered to the company. An analysis of the deposit methods is carried out in order to ensure the absence signs of suspicious activity and ensure compliance with Risk Prevention procedures. Money Laundering.
2. Client Identification Customer identification constitutes an essential element of the customer policy. "Know Your Customer" (KYC). In the context of this document, a Customer is referred to as: The person or entity that holds an account with the firm or in whose name an account is maintained, i.e. the beneficial owners. The beneficiaries of transactions carried out through professional intermediaries. Any individual or entity linked to financial operations that may represent a risk significant to the reputation or other aspects of the organization.
The company implements a systematic procedure to detect and confirm the identity of new Clients, ensuring that a service relationship is not established until verification of the Client's identity is satisfactory.
The company is obliged to collect specific information and verify the identity of Clients, including all authorized signatories, in accordance with our policy, before proceeding to the opening an account.
The company pays special attention to non-resident Clients and, without exceptions, does not avoid in any case previously established identification procedures. This applies even when the new Client cannot present the documentation and information necessary to comply with the procedures of Know Your Customer (KYC) of the company.
Customer identification is carried out automatically when opening an account. To guarantee the updating and agreement of the records with the Client's information, The company will maintain regular communication with it to make the necessary updates. Additionally, the Client is expected to inform the company of any changes in your residence or information. relevant personnel. An opportune time to do so is when the Client makes a significant transaction, c When Client's documentation standards change substantially or when a material change occurs in account operations.
However, if at any time the Anti-Money Laundering and Anti-Financing Supervisor Company Terrorism (AML/CFT Supervisor) identifies that there is insufficient information about a Existing customer, immediate steps will be taken to obtain all relevant information as soon as possible. as soon as possible in order to update the Client's account. Otherwise, this will result at account closing. In situations where the lack of information provided by the Client may compromise the reputation of the Company, a more exhaustive search will be carried out by the nature of the transactions carried out and for deeper scrutiny.
Private accounts, which by their nature require a high level of confidentiality, They can be opened in the name of individuals, commercial companies, trusts, intermediaries or personalized investment companies. In each case, there is reputational risk if the firm does not strictly follows the established KYC procedures. Approval of all new Clients and accounts falls to the corresponding department, the firm's Client financial manager or the designated AML/CFT manager thereof. In the case of new Clients considered high risk, The final decision is made by the CEO of the firm. Specific internal procedures have been established to protect the confidentiality of Clients and their operations. The company will ensure that equivalent due diligence and monitoring of these Clients and their businesses, and that such information is available for review by the AML/CFT Manager and auditors.
The company has well-defined policies and guidelines on record retention for the identification of Clients and individual transactions. This practice is essential for the company can monitor its relationship with the Client, understand its ongoing commercial activity and, if necessary, have evidence in litigation situations, legal actions or investigations financial matters that could lead to criminal proceedings.
As part of the initial and follow-up process of Customer identification, The Company acquires identification documents from the Client and keeps copies of them for a period of time. period of at least five years after closing an account. In addition, Fibra FX retains all the records of financial transactions for a period of at least five years from the date on that concludes Fibra FXF's relationship with the Client or completes a transaction.
In the event that the insufficiency of information provided by the Client represents a risk to the Company's reputation, the Company will be forced to conduct a more detailed investigation. This is due to the nature of the transactions managed and for the purpose of subjecting them to more rigorous scrutiny.
Private accounts, characterized by requiring a high level of confidentiality, can be opened to name of individuals, business companies, trusts, intermediaries or custom investment companies. In each case, there is a risk of reputational damage if the firm does not strictly follow procedures. KYC established. Approval of all new Customers and newly created accounts must be approved by approval of the corresponding department, the firm's Client financial manager or the manager designated AML/CFT of the same. In the case of a new Client considered high risk, the decision ultimately falls to the CEO of the firm. The company has established specific internal procedures to safeguard the confidentiality of Clients and their activities. The company will guarantee the realization due diligence and equivalent monitoring of these Clients and their operations, and will make available this information for review by the AML/CFT Manager and auditors.
