Efy Finance

Anti-Money Laundering and Countering the Financing of Terrorism (AML) Policy

EFY Finance's AML Policy is designed to prevent money laundering, including the need to have appropriate systems and controls in place to mitigate the risk of the business being used to facilitate financial crime.

This AML Policy sets out the minimum standards that must be met and includes:

The appointment of an allied company that is capable of identifying money laundering activities (MLRO), has sufficient seniority and independence and has responsibility for monitoring compliance with relevant legislation, regulations, standards and industry guidance; Establishing and maintaining a Risk Based Approach (RBA) to assess and manage money laundering and terrorist financing risks to our company; Establishing and maintaining risk-based Due Dilligence, identification, verification and know your customer (KYC) procedures, including manual and enhanced Due Dilligence for those clients who present higher risk, such as Politically Exposed Persons (PEPs); Establishing and maintaining risk-based systems and procedures to monitor ongoing client activity; Procedures for reporting suspicious activity internally and to relevant law enforcement authorities as appropriate; Maintaining appropriate records for the prescribed minimum periods; Due Dilligence, Training and Awareness of all employees of the company. Countering the Financing of Terrorism (CFT) The Company takes a risk-based approach when adopting and implementing countering the financing of terrorism (CFT) measures and in conducting AML risk assessments. The Company has adopted internal CFT (Combating the Financing of Terrorism) controls and has made decisions regarding CFT matters that supersede 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, individuals or representatives of any entity must be identified with a passport and/or identity 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 must be made and filed in files securely.