KYC and AML Policies

Introduction

FCMlab OÜ, registered as Private limited company (PLC) on 14.02.2019 under number 14662130 at Harju maakond, Tallinn, Põhja-Tallinna linnaosa, Randla tn 13-201, 10315, hereinafter referred to as FCMLab, follows KYC and AML policies, according to the applicable law, for the purpose of countering money laundering and the financing of terrorism.

Money laundering is a process by which criminals conceal the illicit origin of their assets. Criminals are looking for a way to break the link with a crime and to hide the source of funds or assets obtained by criminal means. This is achieved by changing the form of criminal property, creating complex ownership structures, choosing jurisdictions with less stringent anti-money laundering requirements or a combination of these methods.

We adhere to high AML (Anti Money-Laundering) standards to prevent the use of our products and services for money laundering purposes. The standards set forth in this Policy are the minimum necessary standards and are based on applicable legal and regulatory requirements. These standards are established to prevent the unlawful use of FCMLab, our employees, partners and customers for money laundering, financing of terrorism or any other financial crime, and include the following activities:

  • Enterprise-wide risk assessment to determine the Company's risk profile;

  • Establishment of AML policies and procedures;

  • Implementation of internal control throughout its activities aimed at reducing the risks of money laundering;

  • Implementation of “Know Your Client” (“KYC”) procedures for all FCMLAB’s partners and clients;

  • Appointment of a compliance officer fully responsible for AML program;

  • Training of the company’s employees in regard to AML principles.

Know Your Client

We have adopted a risk-based approach during our due diligence procedures in respect of clients in accordance with the applicable KYC and AML regulations.

FCMLab identifies a client by receiving various information about it. Identity verification involves verification of a part of this information on the basis of documents or information obtained from a reliable source independent of the customer. The following information must be obtained to identify the customer (and/or partner):

  • First name and family name;

  • Personal identification number (if any);

  • E-mail address;

  • Mobile phone number;

  • Date of birth;

  • Photo on an official identity document;

  • Residential address; identity document number;

  • Identity document expiry date.

As soon as the client is identified and his/her identity is verified, FCMLab conducts risk assessment and builds further relations with the service consumer, based on the level of assessed risk, up to unilateral refusal to cooperate.

Client’s Transactions and Activity Monitoring

FCMLab continuously monitors the client’s activity and transactions in order to detect suspicious activity. FCMLab does not solely rely on a set of prescriptive rules and thresholds. Instead, it uses a risk-based approach. The solution uses statistical and analytical methods to identify patterns of unusual or suspicious behavior by building profiles for each individual client and comparing their financial activity with expected standard peer groups. This is achieved by using several powerful data analysis tools to detect anything that is beyond “standard”.

We reserve the right to refuse to process a transaction at any stage, especially when we believe that the transaction is somehow related to money laundering or any other type of criminal activity. In accordance with the legislation, we are not obliged to inform the client that suspicious activity has been reported to the relevant law enforcement agencies.

Reporting in the Framework of Maintained Policies

FCMLab has established a method by which its employees consult with their line managers to assess the relevancy of subsequent information disclosure. This in no way prevents an employee from direct contact with the company’s client (and/or partner). All internal reports are recorded as appropriate.

Reporting is prepared in such a way to provide each known fact with a reasonable and accurate estimate. The assigned employee assesses the risk associated with the transaction or activity. In situations where there are linked accounts, it is necessary to verify such relationship. If an internal audit has shown sufficient grounds to know or suspect that any benefit has been gained, and if criminal property exists, an external report to law enforcement agencies is drawn up.

We keep records of the identity of all clients, identity documents (in each case, including originals and any updated records), details of FCMLab’s business relationship with them and details of any incidental transactions, according to regulatory requirements, for at least three years from the date of termination of business relationship or from the date of the last transaction.

Advanced Training

All FCMLab’s employees are aware of the AML and KYC programs. Our requirement is that the training is conducted for all employees (new and current ones) prior to the start of employment activities and should at least include:

  • Understanding and recognizing money laundering and fraud;

  • Verification of client identification;

  • Detection of any suspicious activity and structured transactions;

  • Reporting requirements for all transactions;

Additional training is provided regularly to all employees based on changes in government regulations, FCMLab’s AML compliance program requirements, relevant procedures and policies, or in case of performance issues related to KYC and AML policies.