WebitPad2

Aml & Cft policy

LAST UPDATED: 15.10.2024

Our company is committed to upholding the highest standards of integrity and compliance with anti-money laundering (AML) and counter-terrorism financing (CFT) regulations in accordance with the laws of Romania. We are dedicated to preventing illegal activities and maintaining the integrity of financial transactions within our jurisdiction.

We utilize the services of a third-party provider for Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance. By using our services, you acknowledge and agree to the implementation of AML and KYC measures by such third-party services. You understand and accept that we are not responsible for any actions, errors, or omissions of the third-party provider. By agreeing to these terms, you declare that you acknowledge and accept this disclaimer.

  1. Regulatory Framework

Our operations are governed by the laws and regulations of Romania, including The Government Emergency Ordinance no. 111/2020 which amends Law no. 129/2019 on preventing and fighting money laundering and the financing of terrorism, and any guidelines issued by the European Commission (EC) and other relevant authorities.

  1. Risk Assessment

We conduct comprehensive risk assessments to identify and mitigate potential risks associated with money laundering and terrorist financing. Our risk assessment methodologies are designed to evaluate customer profiles, transaction patterns, and other factors to ensure compliance with regulatory requirements.

  1. Customer Due Diligence (CDD)

We adhere to stringent customer due diligence procedures to verify the identity of our customers and assess the nature and purpose of their transactions, as well as the source of their income and other related information. This includes obtaining identification documents, conducting background checks, and monitoring transaction activities for suspicious behavior. The CDD measures implemented by our third-party provider encompass the following key processes:

3.1. Legal Person/Arrangement

For legal persons or arrangements, customers are required to provide the following documents:

a. Certificate of Incorporation or equivalent.

b. Articles of Association or equivalent, which should show the shareholders and directors of the legal person/arrangement.

c. Certificate of Good Standing or equivalent if the entity is greater than 12 months old.

d. ID Document for directors, representatives, and ultimate beneficial owners (UBOs), which shall represent a government-issued Passport or other National ID, bearing a photograph of the individual.

e. Proof of residence for directors, representatives, and UBOs, which shall be no greater than three (3) months old (utility bill, bank statement).

f. Confirmation for no public office held or official political affiliation, or details if contrary.

g. In case of a complex ownership structure, an organization chart (up to the UBOs) should be provided.

3.2. Individuals

For individuals, customers are required to provide the following documents:

a. ID Document, which shall represent a government-issued Passport or other National ID, bearing a photograph of the individual.

b. Proof of residence, which shall be no greater than three (3) months old (utility bill, bank statement).

c. Confirmation of no public office held or official political affiliation, or details if contrary.

d. Selfie provided live or uploaded through the KYC Portal.

e. Job title.

f. Annual income and source of funds.

3.3. Representative/Signatory for the Customer

If the capacity of the representative does not result from the documents submitted as per Clause 3.1, the Client shall provide:

a. A power of attorney, or

b. A board resolution of the entity along with evidence that the nominated individual may represent the entity in the relationship with the Contractor.

  1. Transaction Monitoring

We employ robust transaction monitoring systems provided by our third-party provider to detect and report any suspicious or unusual activities that may indicate money laundering or terrorist financing. The monitoring processes are designed to identify patterns, trends, and anomalies in transactional data to mitigate risks effectively.

  1. Reporting Obligations

We are committed to fulfilling our legal obligations to report suspicious transactions and activities to the NATIONAL OFFICE FOR THE PREVENTION AND CONTROL OF MONEY LAUNDERING and other relevant authorities in Romania. We promptly file suspicious activity reports (SARs) and collaborate with law enforcement agencies to combat financial crime.

  1. Training and Awareness

We provide comprehensive training and awareness programs to our employees and stakeholders to ensure they understand their roles and responsibilities in combating money laundering and terrorist financing. Our training initiatives promote a culture of compliance and vigilance throughout our organization.

  1. Compliance Monitoring and Internal Controls

We maintain robust compliance monitoring mechanisms and internal controls to assess and enhance the effectiveness of our AML/CFT program. Regular audits, reviews, and assessments are conducted to identify areas for improvement and ensure ongoing compliance with regulatory requirements.