Trustsend LTD
Reg. No. ΗΕ 456451
Registered address: Agias Philaxeos 131, office 301, 3083 Limassol, Cyprus
Anti-Money Laundering and Know-Your-Customer Internal Policy
2024
TERMS
Company Trustsend LTD
Customer A legal person or association of such persons,
whom the Company submits, or who wishes to
receive Services from the Company
FCA The Financial Conduct Authority
EU The European Union
PSP Payment Service Provider
EMI Electronic Money Institution
AML Anti-Money Laundering
ML Money Laundering
CFT Counter-terrorist financing
FT Terrorism financing
CDD Client (Customer) Due Diligence
EDD Enhanced Due Diligence
NCA national law enforcement agency in the United
Kingdom responsible for pro-active operations
against serious and organized crime
SAR Suspicious Activity Report
PEP Politically Exposed Person
INTRODUCTION
This document sets out the principles and standards for compliance and management of risks
associated with financial crime in Trustsend LTD (the Company). The purpose of this document is
to prevent Trustsend LTD from being used for financial crime to comply with all applicable legal
requirements and to ensure that the most appropriate action is taken by Trustsend LTD to mitigate
the risks associated with financial crime.
This document outlines the applicable legal requirements related to financial crime to which the
Trustsend LTD must adhere, as well as internal measures that are established by Trustsend LTD to
ensure it complies with these legal requirements. This document is referred to as the AML and CFT
and Sanctions Policy and sets the parameters for Trustsend LTD in relation to the AML, CFT and
sanctions framework.
The Policy applies to all Company employees, all units in the Company, senior management,
foreign correspondents, contractors and third parties with whom the Company may contract with.
The aim of the Company is not only to comply with relevant legal requirements, but also to mitigate
and reduce the potential risk to the Company of its customers using Company’s products, services
and delivery channels to launder the proceeds of illegal activity, fund terrorist activity or conduct
prohibited financial sanctions activity.
This AML policy is elaborated in accordance with:
• FAFT (Financial Action Task Force) recommendations on AML and CFT
• Terrorism Act 2000
• Anti-terrorism, Crime and Security Act 2001
• Proceeds of Crime Act 2002
• Serious Organised Crime and Police Act 2005
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer)
• Regulations 2017
• Money Laundering and Terrorist Financing Regulations 2019
• Sanctions and Anti-Money Laundering Act 2018
• JMLSG (Joint Money Laundering Steering Group) Guidance
The Company’s Management Board is liable for implementation of this AML policy, allocation of
sufficient financial resources, attraction of qualified employees, organization and supervision of
controls.
The Policy must be updated at least once a year, or more frequently based on international
requirements and legislative changes.
The procedures contained within this policy relate to all Customers of the Company.
The Company’s Management Board designates one of its members who is directly responsible for
monitoring AML / CFT legislation and the implementation of AML policy.
The purpose of preventive measures taken by the Company is:
• to analyse requirements of the Company’s internal regulations and the actual performance
thereof in order to identify imperfections in the existing system or performance (employees);
• to improve internal regulations, training of responsible employees.
In addition to Management Board and the employees of the Company are also responsible for
implementing respective aspects of this policy.
1. CLIENT`S DUE DILIGENCE
1.1. Client`s due diligence is the processes used by the Company to collect and evaluate relevant
information about a Client or potential client. It aims to uncover any potential risk to the Company
of doing business with a Client or potential client by analyzing information from a variety of
sources. These include:
• Clients themselves, who needs to provide certain information in order to do business with the
Company;
• Sanctions lists published by governments or territories;
• Public data sources.
1.2. The overarching goal of the Client's Due Diligence is to obtain assurance that the funds
involved in Client`s activity have not been obtained by criminal means, the purpose of Client`s
activity is not related to money laundering attempts or Client`s activity will not be used to finance
terrorism or proliferation.
1.3. In order to implement the overarching goal referred to in Clause 1.2., the main goal of the
Client's Due Diligence is to determine the Client's risk in connection with the possibility of money
laundering or terrorist or proliferation financing.
1.4. The Company will take reasonable steps:
1. to check Client`s corporate data, its business reputation using reliable, independent source
documents, data or information;
2. to identify the ultimate beneficial owner of the Client, and take reasonable measures to verify
the identity of the beneficial owner. This should include understanding the ownership and
control structure of the Client;
3. to understand and, as appropriate, to obtain information on the purpose and intended nature
of the business relationship;
4. to conduct ongoing due diligence on the business relationship and scrutiny of transactions
undertaken throughout the course of that relationship to ensure that the transactions being
conducted are consistent with the Company`s Policy and KYC, business and risk profile,
including, where necessary, the source of funds.
1.5. The Company will keep at all times a secure list of all its Clients and information and
documents will be retained. Company is committed to ensuring that its business operates with the
highest degree of integrity and in compliance with those that prohibit money laundering, terrorist
financing, corruption, bribery and other criminal conduct.
1.6. For the purposes of the Due Diligence before entering business relation with Client, the
following documents should be provided:
Information and copies of the documents certifying company's good standing:
• Certificate of incorporation;
• Memorandum and articles of incorporation;
• Good standing certificate (not older than 6 months);
• Valid license certificate (or evidence of applications pending, if a license is not issued yet);
• Copy of Operator’s AML/CFT policy;
• Copy of Operator’s anti-bribery, anti- fraud and anti-corruption policy.
Information and copies of the documents certifying legal ownership structure of the company, its
directors, officers and shareholders:
• Certified director registry;
• Certified shareholders register (certification not older than 6 months), if the respective
information is not included in the good standing certificate;
• Structure chart certified by director (not older than 6 months).
Information and personal ID document copies of the UBO of the company:
• Identification document – copy of a certified (not older than 6 months) international
identification document (e.g. passport);
• Proof of address – copy of a certified document not older than 6 months (e.g. utility bill).
Information and personal ID document copies of the Director of the company:
• Identification document – copy of a certified (not older than 6 months) international
identification document (e.g. passport);
• Proof of address – copy of a certified document not older than 6 months (e.g. utility bill).
1.7. The identification documents are only accepted in high quality as a scan, photocopy or a
photograph; all four corners of the document should be visible, and in case of ID cards – both sides
should be provided.
The document should not be accepted in the following cases:
• When it is difficult to read the information in the identification documents due to poor quality;
• When it is difficult to see the photo of the identification document holder due to poor quality;
• When some information and/or part of the document is covered or for any other reason cannot
be seen;
• When only a certain part of the identification document is received;
• When the identification document is received in other language than English and cannot be
read.
The following documents are accepted as the proof of address:
• correspondence from a central or local government authority, department or agency;
• an official conduct certificate;
• any other government-issued document not mentioned above;
• a lease contract or agreement;
• Utility bill (gas/electricity/home internet) – not older than 3 months;
• a bank statement or a reference letter issued by a recognized credit institution or entity – not
older than 3 months.
The document should not be accepted in the following cases:
• When the received document is older than 3 months;
• When it is difficult to read the information in the identification documents due to poor quality;
• When some information and/or part of the document is covered or for any other reason cannot
be seen;
• When the document is received in other language than English and cannot be read;
• When the name on the proof of address does not match the name in the identification
document.
In cases when the inappropriate or insufficient document is received – another copy and/or
document should be received in order to complete the verification procedure.
1.8. If any significant information of a Client changes, verification documents will be requested.
1.9. If the beneficial owner is a politically exposed person, a relative or a person closely associated
with the politically exposed person:
• must obtain permission from senior management to enter into or continue a business
relationship;
• all risk-based procedures that identify the source of funds and material well-being of the Client
must be documented.
1.10. Verification and Validation of Source of Funds
Source of Funds validation and verification should be conducted for ongoing monitoring purposes,
as well as with respect to politically exposed persons (PEPs).
Enhanced due diligence and enhanced ongoing monitoring should be carried on when:
• a high risk of money laundering has been identified under the risk assessment or from
information provided;
• Client is from a high-risk country, or operates on high-risk market;
• any other situation which can be assessed as presenting a higher risk of money laundering.
As part of the DD process, the source of wealth should be verified with evidence obtained from the
Client and/or independent source until it is understandable where the Clients’s and/or its UBO
overall wealth has been derived from and (to the best of knowledge) that it's legitimate.
2. PEP (POLITICALLY EXPOSED PERSONS) AND SANCTIONS SCREENING
All UBOs of Client, upon entering business relations, are screened against all sanctions list and
existing PEP lists. Re-screening is also conducted on regular basis.
For PEPs, family members, close associate and entities in which their presence is founded, an
enhanced due diligence must be conducted:
• have approval from senior management for establishing or continuing the business relationship
with that person;
• where the business relationship is entered into, conduct enhanced ongoing monitoring of the
business relationship with that Client.
3. SANCTIONS
3.1. Any potential matches are immediately reviewed and verified prior to onboarding if confirmed
as false matches. If a true match is detected, the onboarding is rejected, and the relationship is
exited. Further actions (such as reporting to the authorities) may be taken on case by case basis and
if required. The Company complies with the following sanctions measures:
• The United Nations (UN) Security Council consolidated sanctions list;
• The EU’s consolidated list of persons, groups and entities;
• The UK HM Treasury (HMT), Office of Financial Sanctions Implementation, “consolidated
list of targets”
• The US Department of the Treasury, Office of Foreign Assets Control (OFAC) sanctions lists
including the SDN list (Specially Designated Nationals and Blocked Persons List);
• Any local government issued list.
3.2. The Company determines the list of jurisdictions with which it does not cooperate, as well as
the list of high-risk countries based on data from the FATF high-risk and other controlled
jurisdictions, the Basel AML Index, the European Commission's list of high-risk third countries, EU
and U.S. sanctions programs, etc.
Non-Cooperative Countries
Sanctions
FATF
Internal decision
High-Risk Countries
Sanctions
FATF
Internal decision
Afghanistan X Albania X
Albania X X Barbados X
American Samoa X Bulgaria X
Anguilla X Burkina Faso X
Antigua and Barbuda X Cameroon X
Barbados X Cayman Islands X
Burkina Faso X Democratic Republic of Congo X
Burundi X Croatia X
Cameroon X Gibraltar X
Cayman Islands X Haiti X
Central African Republic X Jamaica X
Congo D.R. X Jordan X
Crimea and Sevastopol X Mali X
Eritrea X Mozambique X
Ethiopia X Nigeria X
Fiji X Panama X
Gaza Strip X Philippines X
Guam X Russian Federation X X
Guinea X Senegal X
Guinea Bissau X South Africa X
Haiti X South Sudan X
Iran X X Syria X
Iraq X Tanzania X
Jamaica X Türkiye X
Jordan X Uganda X
Lebanon X United Arab Emirates X
Libya X Vietnam X
Macao X Yemen X
Mali X X
Mozambique X
Myanmar X X
Nicaragua X
Nigeria X
North Korea X X
Pakistan X
Palau X
Panama X
Philippines X
Russian Federation X X
Samoa X
Senegal X
Somalia X
South Sudan X X
Sudan X
Syria X X
Tanzania X
Trinidad and Tobago X
Tunisia X
US Virgin Islands X
Vanuatu X
Venezuela X
Yemen X X
Zimbabwe X X
4. THE COMPANY’S INTERNAL POLICY REGARDING CUSTOMER’S HIGH-RISK
OR PROHIBITED ACTIVITIES
The Company shall refrain from establishing any business relations with Customers engaged in any
of the following commercial activities:
• Trade in monetary objects (banknotes) and stamps;
• Provision of money services (e.g., cash desks, currency exchange offices, money transfer
agents or other service providers offering money transfer opportunities);
• Financial services related to loan restructuring, debt recovery, loan amendments, etc.;
• Investment services and incidental investment services;
• Reinsurance and insurance services;
• Provision of cash-in-transit services;
• Crypto currency production (mining);
• Ponzi schemes; Financial pyramid;
• Drugs and drug paraphernalia, narcotic or narcotic-like substances;
• Operation of drug stores and pharmacies, trade in medications, patented drugs and
pharmaceutical products;
• Trade in tobacco products;
• Trade in weapons and munitions;
• Trade in jewelry, precious metals and precious gems;
• Trade in antique items and art objects;
• Illegal / pirated audio or video records;
• Hosting, file copying, unlicensed IPTV;
• Counterfeit (forged) goods;
• Goods and services of sexual nature, Adult;
• Intermediation in real property transactions;
• Unofficial charity, political or religious organisations, ICO and Crowdfunding;
• Binary Options;
• Multi-level marketing (MLM);
• Enter into/maintain business relationships with individuals or entities known or suspected to
be a terrorist or a criminal organisation or member of such or listed on sanction lists;
• Maintain anonymous accounts, accounts for shell banks or pay-through accounts.
5. RISK-BASED CUSTOMER DUE DILIGENCE AND RISK PROFILING
Risk of all the Clients shall be categorized into 3 different categories: High Risk, Medium Risk and
Low Risk based on their risk profile considering certain indicative criteria to avoid money laundering
and other compliance risk.
5.1. Low Risk: Clients, their UBO`s and Director whose identities and sources of wealth can be
easily identified and transaction maintained by such customer is done via bank account shall
be categorized as "Low Risk".
5.2. Medium Risk: Clients, their UBO`s and Director who are conducting normal nature of wealth
but lack sufficient information and documents for categorizing under 'Low Risk' shall
normally be categorized as medium risk. Besides, all Clients who do not fall under the category
of either High Risk or Low Risk profile shall also be categorized as Medium risk.
5.3. High Risk: Clients, their UBO`s and Director that are likely to pose a higher risk depending
on their background, sources of funds etc. can be categorized as high risk. Also as High Risk
Clients should be categorized Clients, who make payments using cryptocurrencies. Some of
the indicative list of High Risk Clients are:
• Clients having unusual amount of transactions, including transactions in Games.
• Any related person who is suspected for directly or indirectly assisting terrorism, terrorist
activities, terrorist organizations, organized crimes, illicit drugs and any other criminal
activities. Normally the Company should not establish business relationship with such
Clients.
• Firms, companies, organizations, agencies or entities, established and being operated
without Regulatory or supervisory Authority.
• Clients, their UBO`s and Director who have been generally known through public media
to be involved in Money Laundering and other financial crimes.
• Clients, their UBO`s and Director, who have been understood / heard to be involved in
evading or misappropriating tax, customs, fees or any other revenue.
• Clients, their UBO`s and Director are residents of the country, which is classified as non-
cooperative country by Financial Action Task Force (FATF).
• Clients, their UBO`s and Director are nationals of a country, which has not adopted
necessary standards of AML/CFT.
• Clients, their UBO`s and Director are citizens of the country which is not serious on the
matters of customer identification.
• Clients, their UBO`s and Director are citizens or institutions of a country on which the
United Nations or any Inter Governmental International Organizations has imposed
sanctions or warns.
• Clients or its Players whose transactions are suspicious on the basis of normal course of
business.
• Clients, their UBO`s and Director are connected to the PEP.
6. DOCUMENTATION STORAGE
6.1. For at least five years after the termination of the business relationship, the Company keeps:
• all information obtained within the Due Diligence process;
• information on all payments made by the Clients;
• correspondence with the Clients on corporate and financial issues, including electronic
correspondence.
6.2. At the end of the storage period, the Company destroys the Clients documents and other
information about Client in its possession. The period of storage of Client`s information begins after
the termination of the business relationship.
7. TRAINING PROGRAMS
7.1. The Company ensures that its employees are adequately trained and informed about the
requirements set out in Company’s AML/CTF and Sanctions policies and procedures. The Company
also ensures that the daily duties of its employees are executed in accordance with Company's
regulations and technical instructions specified in Company's AML/CTF and Sanctions procedures.
An employee of the Company, who violates AML/CTF regulatory documents or acts illegally in the
course of performance of his/her duties, shall be subject to disciplinary sanctions, as stipulated in
Company's rules of internal order, and to the liability, as provided for in the regulatory enactments of
the United Kingdom.
7.2. Employee AML/CTF and Sanctions training is comprised of two key elements:
7.2.1. Induction Training – the senior management is responsible for identifying relevant new staff
that are required to undertake induction training within 45 days after commencement of employment
relationship. The training is provided by the responsible employee or an external service provider and
is a face to face training. The contents of the training include awareness training, covering ML/TF and
Sanctions. Until a new member of staff has been signed off as competent, no direct client contact is
allowed;
7.2.2. Refresh Training - all relevant staff must undertake a face to face refresher or online training at
least an annual basis. The training is provided by the responsible employee or an external service
provider, and assessment of staff understanding is carried out throughout the training.
The training includes also:
7.2.3. how to identify red flags and signs of money laundering that arise during the course of the
employees’ duties;
7.2.4. what to do once the risk is identified;
7.2.5. what employees’ roles are in the Company’s compliance efforts and how to perform them;
7.2.6. the Company’s record retention policy; and
7.2.7. the disciplinary consequences for non-compliance with legislation.
7.3. The Company develop ongoing employee training under the leadership of the responsible
employee or an external service provider and senior management. The training occurs on at least an
annual basis. It based on the Company’s size, its Client base, and its resources and be updated as
necessary to reflect any new developments in the law.
8. STAFF DUE DILIGENCE
It is imperative that the Company’s employees are of undisputed integrity. To ensure this objective,
the Company follows a procedure whereby all applicants must produce a curriculum vitae, at least
two references and relevant educational qualification certificates, and/or professional certificates,
which are checked and verified by the Company’s Human Resources Department.
