Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT) Policy
EFY Finance’s AML Policy is designed to prevent money laundering, including the need to have adequate systems and controls in place to mitigate the risk of the company being used to facilitate financial crime.
This AML Policy establishes the minimum standards that must be met and includes:
The appointment of an allied company that is capable of identifying Money Laundering activities (MLRO), that has a sufficient level of seniority and independence and that has the responsibility of monitoring compliance with legislation, regulations, standards and relevant industry guidance;
Establish and maintain a Risk Based Approach (RBA) to assess and manage money laundering and terrorist financing risks to our company;
Establish and maintain risk-based Due Diligence, identification, verification and know-your-customer (KYC) procedures, including manual and enhanced Due Diligence for those customers who present higher risk, such as Politically Exposed Persons (PEP);
Establish and maintain risk-based systems and procedures to monitor ongoing customer activity;
Procedures for reporting suspicious activities internally and to relevant law enforcement authorities as appropriate;
Maintaining appropriate records for minimum prescribed periods;
Due Diligence, Training and knowledge of all company employees.
Combating Counter-Terrorism Financing (CFT)
The Company takes a risk-based approach when adopting and implementing counter financing of terrorism (CFT) measures and in conducting AML risk assessments.
The company adopted internal CFT (Combating the Financing of Terrorism) controls and made decisions regarding CFT matters supersedes any business, strategy or other operational tasks if necessary.
International Sanctions Policy (ISP)
Our company is prohibited from conducting transactions with individuals, companies and countries that are on recognized sanctions lists.
(KYC) Know Your Customer
In order to carry out transactions on our site, people in their personal capacity or on behalf of any entity must be identified with a passport and/or citizenship card and a photo validation document with a biometric identification system that allows the official document to be compared with the documentation. presented. Companies must be identified by certifications from the Public Registry, extracts from the Chamber of Commerce or similar documents in the applicable jurisdiction. Copies should be made and stored securely in archives.