1.1. This AML Policy is developed in strict accordance with the latest standards set by the FATF and OECD, as well as global and domestic anti-money laundering legislation.
1.2. These internal regulations govern the monitoring and disclosure of financial operations and documentation to prevent money laundering and the financing of terrorism.
1.3. This policy establishes the mandatory procedures and internal control obligations for all Armax.capital employees to mitigate financial crime risks.
2.1. Effective policy implementation is managed by a specialized oversight group comprising a board member, the head accountant, and the head of the legal department.
2.2. While initial client identification is managed by relevant business units, all subsidiaries are directly accountable to this oversight group regarding the handling of suspicious activities.
3.1. Control measures are applied to identify clients and evaluate risk profiles throughout the duration of the commercial relationship.
3.2. Data collection is strictly limited to the purposes defined in this policy. We prohibit unauthorized usage or third-party disclosure of information unless mandated by law.
4.1. We verify the identity of both natural persons and legal entities using official documentation. This includes determining if a client holds a “state official” (PEP) status.
4.2. All provided information is cross-referenced with public registries, official databases, and state authorities to ensure authenticity.
4.3. Legal entities must be registered by an authorized representative who can provide verified legal proof of their power to act on behalf of the entity.
5.1. Every client and proposed transaction undergoes a rigorous risk evaluation regarding money laundering and terrorism financing.
5.2. Clients are assigned risk tiers based on these factors. Armax.capital reserves the right to deny services or terminate cooperation in cases identified as high-risk.
6.1. No commercial relationship is finalized until the client explicitly agrees to comply with this AML Policy.
6.2. If a client operates through a representative, the Company takes steps to verify the legitimacy of that relationship and ensures direct communication channels are established.
7.1. If a transaction is suspected of being linked to financial crime, all cooperation will be suspended immediately.
7.2. If immediate denial of a transaction would jeopardize a client's safety or an ongoing investigation, we may delay the denial while filing a mandatory report with the Financial Inspection authorities.
8.1. Management may initiate information exchanges with third parties, such as banking institutions, formalized through bilateral agreements.
8.2. These exchanges include specific details regarding the control methods and security protocols employed by both parties.
9.1. All employees involved in transaction processing are required to document and archive every transaction detail according to our internal recording program.
10.1. We reserve the right to refuse any transaction if a client fails to provide the requested documentation. Decisions may be reversed only upon the submission of satisfactory information.
11.1. To ensure total compliance, all staff must complete an AML and terrorism financing prevention training program within their first month of employment.
12.1. We conduct regular internal audits to confirm that all employees are adhering to both national legislation and the company's internal rules regarding income legalization.
13.1. In compliance with legal standards, all identification records and transaction history are securely archived for a minimum of five (5) years, including any records reported to state regulators.