The 5%ers AML Policy

Anti-money laundering policy

As a company, Five Percent Online Ltd. (“The Company”, “We”, “Our”, “Its”) is committed to the highest standards of anti-money laundering (“AML”) compliance. The Company requires Its management and employees to adhere to and comply with all applicable laws and regulations aimed at combating money laundering and terrorist financing, and at preventing use of Its products and services for money laundering purposes. 

This Policy explains the Company’s individual responsibility in complying with anti-money laundering and counter-terrorist financing laws (“AML Laws”) around the world, and ensuring that any third parties with whom we engage to act on our behalf, do the same. 

Five Percent Online Ltd. will examine Its Anti-Money Laundering strategies, goals and objectives on an ongoing basis and maintain an effective Anti-Money Laundering Policy for the Company’s business that reflects the best practices for a diversified, global financial company. Adherence to the Company’s Anti-Money Laundering Policy is the responsibility of all employees.

This Policy includes client screening and monitoring requirements, “Know Your Customer” (“KYC”) policies (including the requirement to establish the identity of beneficial owners), Embargo policies, record keeping requirements, the reporting of suspicious circumstances in accordance with relevant laws, and training.

This Policy is intended to help employees, contractors, and other third parties acting on the Company’s behalf to understand where breaches of AML Laws might arise, and to support them in making the right decisions in line with our corporate position as stated in this Policy.

Scope

  • Objectives
    The standards set out in this Policy are minimum requirements based on applicable legal and regulatory requirements, and apply for the entire Five Percent Online Ltd. These requirements are intended to prevent the Company, Its employees and clients from being misused for money laundering, terrorist financing or other financial crime. This Policy establishes the general framework for the fight against money laundering and financing of terrorism.
  • Applicability
    According to the Anti-Money Laundering Act 2006, Five Percent Online Ltd. must ensure that the legal duties resulting from the regulations set out in this Act are fulfilled by Our subordinated enterprises, branches, subsidiaries and affiliates in the UK, in Israel and abroad. Wherever local regulations are stricter than the requirements set out in this Policy, the stricter standard has to be applied. If any applicable laws are in conflict with this Policy, the relevant Five Percent Online Ltd. entity must consult with the local legal department to resolve the conflict. If the minimum requirements set out in this Policy cannot be applied in a certain country because application would be against local law, or cannot be enforced due to other than legal reasons, Five Percent Online Ltd. has to assure that it will not enter into a business relationship, continue a business relationship or carry out any transactions. If business relations already exist in that country, Five Percent Online Ltd. has to assure that the business relationship is terminated regardless of other contractual or legal obligations.
  • Definition of the Term Money Laundering
    Money Laundering is the participation in any transaction that seeks to conceal or disguise the nature or origin of funds derived from illegal activities such as, for example, fraud, corruption, organized crime, or terrorism etc. Predicate offences for money laundering are defined by local law. Generally speaking, the money laundering process consists of three “stages”:
    • Placement: The introduction of illegally obtained monies or other valuables into financial or nonfinancial institutions.
    • Layering: Separating the proceeds of criminal activity from their source through the use of layers of complex financial transactions. These layers are designed to hamper the audit trail, disguise the origin of funds and provide anonymity.
    • Integration: Placing the laundered proceeds back into the economy in such a way that they reenter the financial system as apparently legitimate funds.

These “stages” are not static and overlap broadly. Financial institutions may be misused at any point in the money laundering process.

Procedure manual

  • Client Identification Procedures
    As part of the Company’s AML Policy, the Company has established procedures to ensure that all clients’ identities are verified prior to receiving payout commissions as a contractor. Before opening a contractor account for an individual client, Five Percent Online Ltd. will require satisfactory documentary evidence of a client’s name, address, date of birth, and either but not limited to the following forms of identification:
    • Passport or National ID
    • Proof of address
    • Any other relevant documentation as required by the local tax authorities

Prohibited clients

Five Percent Online Ltd. will not open accounts or accept funds or securities from, or on behalf of, any person or entity, nor will it accept high-risk clients (with respect to money laundering or terrorist financing) without conducting enhanced, well-documented due diligence regarding such prospective clients.

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