Montify LTD (the “Firm”) is a company registered  in England  and Wales under registration number: 12230765, with a Registered Office and Trading Address at New London House, 6, London Street, London, England, EC3R 7LP. The Firm is authorised and regulated by the Financial Conduct Authority ("FCA") as an Authorised  Electronic Money Institution (“EMI”) under the second Payment Services Directive (“PSD II”), with FCA Firm Reference Number (“FRN”) 901069.


The Firm’s Anti-Money Laundering and Counter-Terrorist Financing Policy (the “Policy”) is designed to prevent and mitigate possible risks of the Firm being involved in any kind of illegal activity. The Firm is committed to high standards of Anti-Money Laundering and Counter- Terrorist Financing (“AML / CFT”) compliance and requires management and employees to adhere to these standards  in preventing the use of its products and services for money laundering (“ML”) or terrorism financing (“TF”) purposes.

The Firm reserves the right to reject any customer, payment  or business that is not consistent with the Firm’s AML Policy subject to the requirements of the applicable AML laws and regulations.


Adherence to Applicable AML Laws and Regulations

In accordance with AML regulations, the customer is required  to provide the Firm with accurate and complete information and documentation that assists in determining the customer’s identity and verifying the customer, as well as information on payers and payees of each monetary operation and transaction processed through the customer’s account in the Firm. The customer may be required to provide to the  Firm  additional information or documents regarding the customer, respective monetary operation or other transaction, or counterparty of such transaction.


Know-Your-Customer

The Firm’s Know-Your-Customer (“KYC”) principles require due diligence on each prospective customer before entering a business relationship via identification and verification of customers’ identity, representatives, and beneficial owners based on documents, data, or information obtained from a reliable and independent source compliant with the domestic and European AML / CTF legislation and regulation.

Primary objectives by gathering KYC information, using a risk-based approach:

  • Identifying the customer.
  • Verifying the client’s identity.
  • Understanding the customer’s activities and source of funding.
  • Monitoring the customer’s activities.

Customer Identification

The Firm verifies the identity of the customer and beneficial owner(s) before or during establishing a business relationship. In case  a customer is acting on behalf of another person, the identity of that person shall be ascertained, and relevant documents and information of that person need to be obtained also.

The Firm applies relevant ongoing risk-based measures to verify the identity of each customer and keep necessary records. Customer Due Diligence (“CDD”) procedures are performed on an ongoing basis. CDD measures include collecting all available data on the customer from trusted sources, determining the purpose, intended nature, and key beneficiaries, of the relationship, as well as maintaining ongoing monitoring of the relationship to ensure all activity is consistent with recorded customer information.

The Firm applies Enhanced Due  Diligence (“EDD”) on all  customers who are categorised as high-risk. EDD measures include deeper


investigative research and more intense monitoring of customer activities and transactions. Unusual transactions are reported in suspicious transaction reports.


Risk assessment of customer

Risk assessments are performed on all existing and prospective customers based on information obtained regarding their identity, source of income / wealth, source of funding, location, etc., and based on the results of such assessments, categorise customers among high- risk, medium risk, and low-risk customers.


Source of Funds

The Firm determines the customers’ source of incoming payments and what the funds are going to be used for, to satisfy  itself  that  the money has not been derived from or is not going to be used  for criminal activity.

To determine the origin or source of incoming funds, the Firm asks the customer to fill in the source of funds declaration and documents evidencing business operations, registration, or any other proof (e.g., deed of sale, last will and testament, etc.), which may  assist  in verifying the source of funds and the purpose for which the  funds are to be used.


Transaction monitoring

The Firm continuously monitors the activity of every client to identify and prevent any suspicious transactions. The detection of suspicious transactions triggers in-depth investigations of a customer's account. In case of suspicious activity, the client is asked for supporting documentation, and may be reported to the relevant Financial Intelligence Unit (“FIU”).

Suspicious activity includes, but is not limited to, transactions that do not make economic sense for the customer, unusually large transactions, transactions involving unidentified parties, transactions structured to avoid the amount threshold of government reporting


requirements, deposit followed by an immediate request for withdrawal, etc.


Sanctions

To ensure compliance with the applicable sanctions against persons and entities, customers are screened against the following key lists:

  • The HM Treasury / UK Sanctions List (”UK”)
  • The United Nations Security Council Sanctions List (“UN”).
  • The Consolidated List of European Union Financial Sanctions (“EU”).
  • Sanction lists administered by the United States Office of Foreign Assets Control (“OFAC”), including the List of Specially Designated Nationals and Blocked Persons (“SDN” list).
  • Any other available sanctions lists.

In addition, the Firm pays particular attention to entities  from countries that are on lists published by the Financial Action Task Force (“FATF”), and to monetary operations or transactions performed by or on behalf of them. These lists include:

  • High-Risk Jurisdictions subject to a Call for Action; and
  • Jurisdictions under increased Monitoring.

Reporting

The Firm ensures taking appropriate steps to enable suspicious transactions to be recognised and have appropriate procedures for reporting such suspicious transactions. A list of circumstances that are suspicious transactions is given below. This list is only illustrative and whether a particular transaction is suspicious or not will depend upon many factors including details of the transactions and relevant facts and circumstances, and clients who are reticent  to complete  the Firm’s identity verification processes.

  • Asset management services for clients where the source of the funds is not clear or not in keeping with a client’s apparent financial standing or business activity.
  • Clients in high-risk jurisdictions or clients introduced by banks or affiliates or other clients based in high-risk jurisdictions.
  • Substantial increases in business without apparent, valid economic reasons.
  • Unusually large transactions made by an individual or businesses.
  • Transfer of investment proceeds to apparently unrelated third parties.

Record Retention

The Firm retains:

  • Identification and transaction documentation for the minimum period as required by applicable UK laws and regulations.
  • Records of all suspicious activity reports for an indefinite period unless advised otherwise by the Firm’s regulator.

The Firm is required to be positioned to retrieve, within forty-eight

[48] hours and in English, records that are required by the Firm’s regulator or by law enforcement agencies as part of their investigations.