ANTI-MONEY LAUNDERING POLICY
1.
Guiding Laws and Regulations
1.1.
Onetech Group Limited, together with its subsidiaries and affiliated companies (the “Group”), is committed to preventing money laundering and terrorist financing in order to protect the Group’s reputation, its stakeholders and the integrity of the financial system. This Anti-Money Laundering Policy (the “Policy”) has been adopted in accordance with applicable anti-money laundering and counter-terrorist financing legislation and standards, including, without limitation:
(a)
the Prevention and Suppression of Money Laundering and Terrorist Financing Law of the Republic of Cyprus (Law 188(I)/2007), as amended from time to time;
(b)
Directive (EU) 2015/849, as amended (including Directive (EU) 2018/843), as transposed into national law; and
(c)
the Recommendations of the Financial Action Task Force (FATF), as amended from time to time.
1.2.
For the purposes of this Policy, references to “money laundering” include terrorist financing.
2.
Objective
2.1.
The Group’s Policy on the prevention of money laundering applies to all countries where the Group operates and to all business activities within those countries. It constitutes a clear statement to the Group’s employees (the “Employees”), counterparties and regulators regarding the Group’s position on this critical issue.
3.
Risk Assessment
3.1.
The Group adopts a risk-based approach to the prevention of money laundering and terrorist financing. While the nature of the Group’s activities is generally assessed as presenting a low to moderate inherent risk, the Group has adopted this Policy in order to clearly define its controls, responsibilities and procedures, and to ensure that appropriate measures are in place to prevent, detect and respond to money laundering and terrorist financing risks.
4.
Commitment and Control System
4.1.
As an organization committed to the prevention of money laundering, the Group:
4.1.1.
Establishes clear lines of internal accountability, responsibility and reporting. All business areas must ensure that appropriate internal controls are in place and operating effectively, with regular reporting to the Legal Department / Group Legal Director.
4.1.2.
Documents, implements and maintains procedures and controls which give effect to the Group’s Policy and group standards, compatible with the relevant line of business and applicable local laws and regulations.
4.1.3.
Due to the nature of the Group’s business, financial transactions are conducted primarily through reputable and regulated banking institutions. Cash transactions are prohibited, save in exceptional circumstances and only with the prior written approval of Management and the Legal Department / Group Legal Director, supported by appropriate documentation. Where required by applicable law, customer identification and due diligence measures shall be applied in relation to transactions meeting or exceeding the applicable legal thresholds or where transactions appear linked.
4.1.4.
Knowing the Group’s customers and suppliers is of utmost importance in maintaining a secure business environment. The Group, through its local management, takes reasonable steps to verify the identity of its customers, suppliers and, where applicable, their beneficial owners, applying a risk-based approach to customer due diligence and “Know Your Customer” (KYC) procedures.
4.1.5.
Establishes procedures to retain adequate records of identification, and transactions for the minimum period required under applicable law (and in any event not less than five (5) years), which period also applies to records relating to Employees’ training, internal compliance monitoring, and suspicious activity reporting.
4.1.6.
Monitors customer/supplier activity to keep the Group’s records up to date and to report any activity that may involve or presuppose money laundering. This includes using any sort of attained information, whether documented or otherwise obtained.
4.1.7.
Suspends any transaction where reasonable grounds exist to suspect that the operation relates to the proceeds of crime or is to be used for an illegal activity such as terrorism.
4.1.8.
Makes prompt reports of suspicious activity through the appropriate internal channels and where required, to the relevant regulatory and law enforcement authorities.
4.1.9.
Raises awareness on money laundering prevention and trains the Group’s Employees how to recognize and report suspicious activity without exposing themselves to risk or jeopardising any subsequent investigation by the relevant authorities.
5.
Reporting Suspicious Activities
5.1.
Any Employee who has knowledge of, or suspicion regarding, a transaction or activity that may involve money laundering or terrorist financing must promptly report the matter to their local manager and/or directly to the Legal Department / Group Legal Director.
5.2.
The Legal Department/Group Legal Director shall assess the report, request further information where necessary, and determine whether a report must be made to the competent regulatory or law enforcement authorities in accordance with applicable law.
5.3.
The Group shall cooperate fully with lawful requests for information made by competent authorities in connection with investigations into money laundering or terrorist financing.