ANTI-MONEY LAUNDERING/KNOW YOUR CLIENT POLICY
Online store: https://munoden.uno
Company: "IT - CENTER" LLC
Address: HAMID OLIMJON KO'CHASI, 47-UY, Kitab, Uzbekistan
Munoden.uno (further Site, Online store) publishes this Anti-Money Laundering/Know Your Customer Policy (hereinafter referred to as the Policy), which is designed to prevent and reduce the Company’s possible risks associated with involvement it into illegal activities of any nature. Both international and national standards require the Company to implement effective internal procedures and mechanisms for preventing money laundering, financing of terrorism, drug and human trafficking, preventing the proliferation of weapons of mass destruction, corruption and bribery, as well as taking timely measures in case of any suspicious activity of the Site User . Money laundering is defined as actions aimed at concealing or disguising the true origin of proceeds from crime and further legitimizing their receipt. The company actively counteracts any activity that contributes to money laundering. This Policy is intended to ensure that the Company adheres to standards in preventing the use of its products and services by Site Users for the purpose of money laundering. This Policy governs the activities of compliance department employees, as well as verification procedures and risk assessment.
Customer Due Diligence (CDD) is one of the international standards for preventing illegal activity. According to the CDD, the Company establishes its own verification procedures under this Policy.
1.2. Identity verification
1.2.1. The fight against laundering of proceeds from crime lies in the fact that the Company requires the Site Users to provide relevant documents confirming their identity and the method of obtaining funds in order to purchase the relevant products and services.
1.2.2. To complete the identity verification procedure, the Site User must provide the Company with official documents from independent sources or information (for example, a national identity card, an international passport, a bank statement, a utility bill). In order to comply with this Policy, the Company reserves the right to request personal data of the Site User. The Company will take steps to verify the authenticity of documents and information provided by Users of the site. All legal steps will be taken to verify identity. The Company reserves the right to collect information about Site Users who have been classified as dangerous or suspicious.
1.2.3. The Company is not authorized and is not obliged to establish whether the document provided by the Site User for identification is legal. However, in case of obvious inconsistencies in the information received, the Company has the right to require additional documents from the Site User to identify his personality. If the Site User refuses to provide the required information when necessary, or tries to mislead the Company’s employees, this Site User may be denied services.
1.2.4. The Company reserves the right to verify the identity of the Site User on an ongoing basis, especially if the Site User has changed personal data or if his activity seemed suspicious (uncharacteristic for a particular Site User). In addition, the Company reserves the right to request updated documents from Site Users, even if they have previously passed verification.
1.2.6. Once the identity of the Site User is established, the Company may waive potential legal liability in a situation where the services and / or products of the Company are used by the Site User to carry out illegal activities.
1.2.7. If the Company detects signs of suspicious activity of the Site User, which may be related to money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery, information about it will be brought to the attention of the competent authorities.
EMPLOYEE OF THE COMPLIANCE DEPARTMENT
2.1. A Compliance Officer is a person duly authorized by the Company and whose duty it is to effectively implement and enforce this Policy. The duty of an employee of the compliance department is to control all aspects of the Company’s policy on combating money laundering and the financing of terrorism, including:
– collection of personal data of Site Users;
– establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required by applicable laws and regulations;
– monitoring the actions of the User of the site and the study of significant deviations from the standard activities;
– implementation of a records management system for the appropriate storage and retrieval of documents, files, forms and journals;
– Regular updating of the risk assessment;
– Providing law enforcement agencies with the necessary information in accordance with applicable laws and regulations.
2.2. Compliance Officer has the right to interact with law enforcement agencies involved in the prevention of money laundering, terrorist financing and other illegal activities.
MONITORING OF TRANSACTIONS
3.1. The identity of the Users of the site is established by their identification, as well as by analyzing the patterns of their actions. Thus, the Company uses data analysis as a tool for assessing risks and identifying suspicious activity. The company performs many tasks in order to comply with existing requirements, including collecting and organizing data, maintaining records, managing the collection of information and reporting. The functionality of the compliance system includes the following:
– daily checking of Site Users against generally recognized “black lists” (for example, OFAC), merging transfers across multiple data points, placing Site Users on a watch list and denial of services, opening cases for investigation (if necessary), internal communication and completion of mandatory reports (if necessary);
– document management;
– tracking patterns of behavior of Users of the site. In accordance with this Policy, the Company undertakes to monitor all activities and reserves the right to:
– report suspicious activity to law enforcement agencies;
– request any additional information or documents from the Site User in case of suspicious activity;
– suspend or terminate the operation (use) of the Website User’s Personal Account if the Company has sufficient grounds to suspect the Website User of illegal activities;
The list provided is not exhaustive, and the actions of Site Users will be monitored by an employee of the compliance department on a regular basis in order to determine whether transactions are suspicious and should be reported or not.
4.1 The Company, in accordance with international requirements, uses a risk-based approach to combat money laundering and terrorist financing. Thus, the Company can ensure that measures to prevent or reduce money laundering and terrorist financing are commensurate with the identified risks, which is one of its priorities. This will make it possible to allocate the resources of the compliance system in the most efficient way, in particular, they should be distributed in accordance with priorities in such a way that the greatest risks are given the most attention.
5.1. If you have any questions regarding this Policy, you should contact the Information Support Service on the Site.
5.2. Changes and additions to this Policy can only be made by the Company.
5.3. If there are any discrepancies between the various forms (printed, electronic, etc.) of this Policy, the official version is the version posted on the Site in electronic form.
5.4. On the Site, a translation of this Policy into other languages is provided solely for the convenience of Site Users.