The Compliance Program is based on the following pillars formalized through written policies and procedures:
- MLRO Appointment: Designation of a MLRO and ensuring sufficient staffing and resources are present to adequately implement compliance policy in order to reduce the governance risk
- Training: Initial and regular training materials are provided to employees of the company according to the level of responsibility in order to mitigate awareness risk.
- Customer Management: The responsible team is trained to define the level of KYC required and perform the due diligence procedures to ensure that anonymity inherent risk is duly managed.
- Transaction Monitoring: AKOIN has its risk assessed and mitigation processes are designed, developed and implemented to define programs to monitor transactions and report suspicious activity in order to palliate the inherent global reach and disaggregation inherent risk.
- Suspicious activity: Systems for identifying risks, monitoring unusual activity, investigating, reporting suspicious activities are developed and running constantly in order to escalate the vulnerability to the MLRO and the regulators.
- Independent Review: The compliance processes are undergoing regular external audit to ensure the consistency and robustness of the compliance framework. This is to certify that the compliance oversight is properly done.
- Documentation & Record Keeping: Each identification, verification, training, red flags, screening matches, investigations, internal and external reporting are properly documented and records are kept for at least 5 years. It will ensure the traceability.
- Professional behavior: Achieving Efficiency and integrity of Employees: AKOIN had taken procedures that guarantee collecting sufficient information about all employees as well as high ethical standards to insure high levels of efficiency and ethics among them.
Money Laundering Reporting Officer has a pivotal role to play in ensuring that AKOIN is compliant with anti-money laundering obligations.
He also ensures that AKOIN has appropriately considered its exposure to anti-money laundering risks and can respond effectively to those risks in a way which minimizes the likelihood of criminal, civil or disciplinary sanctions.
One of the key components of AKOIN’s effective Compliance Program is employee training, both initial training as well as periodic ongoing training based on the complexity and employee turnover related to the business. training should ensure that employees are aware of the Money Laundering & Terrorism Financing risks faced and their role in mitigating this risk by contributing to the reporting entity's overall compliance with its Compliance obligations.
Know Your Customer (KYC) approach
AKOIN follows strict verification procedures in accordance with customer due diligence and Know your Customer (KYC) standards. As part of the verification process, AKOIN requires the Customer to provide with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). AKOIN reserves the right to request and verify Customer’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular Customer). In addition, AKOIN reserves the right to request up-to-date documents from the Customers, even though they have passed identity verification in the past. Customer’s identification information will be collected, stored, shared and protected strictly in accordance with FATF-compliance procedures & latest directives applying to EU jurisdiction.
A. Standard Due Diligence
Before the customer is authorized to transact, AKOIN will implement a "Know Your Customer (KYC)" process that includes, but is not limited to:
For individual persons:
- Information: telephone number, email address, residential address.
- Identification data/personal details: valid government issued identification with picture; i.e., passport, national ID card, driving license, residency card, employment permit card, etc.
- Proof of residence: a statement not older than 3 months from a utility, service company, licensed corporation or government authority clearly indicating the customer name and residential address conduct occurring at the time of opening the ongoing relationship;
- geographical region of origin;
- purpose for opening the relationship;
- prevailing activity;
- Age: at least 18 years old.
- Customers from countries which are considered as High risk jurisdictions as listed by FATF will not be able to open accounts with AKOIN. For more, please refer to http://www.fatf-gafi.org/publications/high-riskandnon-cooperativejurisdictions/documents/public-statement-june-2018.html
For legal entities:
- Legal Business Entity Name
- Publically traded on one the stock exchanges
- Financial Institutions
- 51% or greater Government owned entity
One Proof of Business:
- Business license or equivalent document
- Certificate of registration
- Certified articles of incorporation
- Prior year business tax return
- Name and contact of person responsible for Anti-Money Laundering (AML) compliance at legal entity level
- Ownership information (Standard due diligence for any individual representing over 10% of ownership)
B. Enhanced Due Diligence
Also in case of any identification doubt, an enhanced due diligence is required. EDD would consist of lowering the risk of the identity fraud by background online checks, requesting additional ID documents, bank documents, proof of address. The requested documents for EDD could be:
- Source of Funds: such as bank Statement clearly highlighting the customer name as the account holder
Purpose of the transaction:
- conduct occurring at the time of completion of the transaction;
- transaction or relationship details;
- significance of the transaction and the relationship.
An EDD will also be conducted when the customer wants to deposit or withdraw fiat currencies to or from AKOIN account, customer will need to go through a detailed verification process as instructed in the website for amounts greater than the designated threshold (in one transaction or aggregated).
Consumer Rights & Data Protection
AKOIN treats its customer fairly and in accordance with the best industry standards as well as in accordance with local regulations. Service terms and conditions are displayed to the customers in order to ensure that customers know what their rights are. These terms and conditions cannot go against the local regulations and best standards in terms of customer management are implemented.
Implementing the provisions of the Directive of the European Parliament and EU Council (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free flow of such data, as well as repealing directive 95/46/EC, AKOIN must safeguard non-public personal information.
AKOIN has adopted a risk-based approach to combating money laundering and terrorist financing.
AKOIN wants to make sure to cover all the measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks.
In most cases, the transactions involved in money laundering are difficult to distinguish from normal, everyday transactions. It is therefore critical that the utmost care and attention is paid to accepting funds, account transactions, and especially large or unusual transactions. Monitoring must focus on unusual transactions, the type of transactions and the nature and frequency of transactions. It is worth to say that monitoring is eased as AKOIN has set some limits:
- Geographical limits for deposits and transfer of funds
- Value limits (per transaction and aggregated)
- Velocity limits (number of transactions allowed per day/week/month)
- Usage limits for payment and deposit
Whilst transaction screening software designed to detect unusual values, volumes and patterns of
transactions may be helpful, transactional patterns alone are unlikely to be considered sufficient
grounds for suspicion.
In order to cooperate with the Authorities to ensure the stability of the financial system and to avoid AKOIN’s involvement in money laundering and terrorist financing, the latter has adopted a structured process for reporting suspicious transactions regarding the illicit origin of transferred funds. For this purpose, AKOIN has identified a reporting party responsible to report suspicious transactions, required to transmit reports to the Financial Intelligence Unit (FIU) in the form and manner required by the Authority
DOCUMENTATION & RECORD KEEPING
All record keeping and reporting documentation required by specific regulations will be maintained for a minimum of five (5) years and they will be made readily available to the regulator and/or representatives from other government officials upon legitimate request especially:
In connection with AKOIN’s continued efforts to prevent money laundering and fraud, meet regulatory requirements and apply international best practices, AKOIN always seeks to continuously enhance its global anti-fraud and anti-money laundering compliance programs. As part of this effort, AKOIN requires to conduct a periodic independent review of its anti-money laundering and anti-fraud compliance programs. The purpose of the independent review is to evaluate the effectiveness of anti-money laundering and anti-fraud compliance programs.
It is necessary to emphasize the importance that AKOIN attaches to the standards of honesty and integrity. These are criteria which all employees are asked to follow throughout the course of their employment. Employees are expected to act in a professional, diligent and loyal manner towards other members of their team as well as towards AKOIN and its Customers, in accordance with laws and regulations in force.
To know more about our AML/KYC policy, please reach out our Support Team