1. General Provisions and Purpose
1.1. This Anti-Money Laundering and Counter-Terrorist Financing Policy (hereinafter referred to as the “Policy”) establishes the principles and procedures applied by Veritas Advisory Group Limited (hereinafter referred to as the “Company”) to prevent the use of its services for money laundering, terrorist financing, and other unlawful activities. This AML Policy, including all terms and provisions, has been individually developed taking into account the Company’s business activities, internal rules, and operational model. The document has been prepared with the involvement of qualified professionals (including legal and audit specialists) and reflects the actual processes applied by the Company in its interaction with website visitors and clients.
1.2. The purpose of this Policy is to ensure compliance with applicable regulatory requirements and to protect the Company from legal, financial, and reputational risks.
1.3. The Company applies a zero-tolerance approach to illegal activities.
2. Scope of Application
2.1. This Policy applies to all employees, consultants, contractors, and partners of the Company.
2.2. The Policy applies to all clients, transactions, and projects at all stages of engagement.
3. Regulatory Framework
3.1. The Company operates in accordance with applicable AML/CTF requirements, including:
3.1.1. European Union Anti-Money Laundering Directives (AMLD);
3.1.2. national legislation of applicable jurisdictions;
3.1.3. FATF recommendations and other international standards.
4. Risk-Based Approach
4.1. The Company applies a risk-based approach when assessing clients and transactions.
4.2. The assessment takes into account:
4.2.1. client jurisdiction;
4.2.2. client type (individual or legal entity);
4.2.3. ownership structure;
4.2.4. nature of the transaction;
4.2.5. other risk factors.
4.3. The extent of due diligence depends on the level of risk.
5. KYC and Customer Due Diligence (CDD)
5.1. Prior to establishing a business relationship, the Company conducts client identification (KYC).
5.2. Due diligence includes:
5.2.1. identification of the client;
5.2.2. verification of ultimate beneficial owners (UBO);
5.2.3. understanding the purpose and nature of the relationship.
5.3. Due diligence may be updated during the course of the relationship.
6. Enhanced Due Diligence (EDD)
6.1. Enhanced due diligence measures are applied in higher-risk cases.
6.2. Such cases include:
6.2.1. complex corporate structures;
6.2.2. offshore jurisdictions;
6.2.3. large or unusual transactions;
6.2.4. politically exposed persons (PEPs).
6.3. Additional documentation and source of funds analysis may be required.
7. Source of Funds and Source of Wealth
7.1. The Company may require verification of Source of Funds and Source of Wealth.
7.2. Where the lawful origin of funds cannot be confirmed, the Company reserves the right to refuse engagement.
8. Ongoing Monitoring
8.1. The Company conducts ongoing monitoring of client relationships throughout the engagement.
8.2. Monitoring includes:
8.2.1. transaction analysis;
8.2.2. tracking changes in risk profile;
8.2.3. updating client information.
9. Suspicious Activity and Reporting
9.1. The Company applies procedures for detecting suspicious activity.
9.2. In case of suspicion:
9.2.1. an internal investigation is conducted;
9.2.2. the matter is escalated to the responsible officer;
9.2.3. where required, a report is submitted to competent authorities.
9.3. The client may not be notified of such actions where prohibited by law.
10. Sanctions and Restrictions
10.1. The Company conducts sanctions screening.
10.2. The Company does not enter into relationships with sanctioned persons or those associated with them.
10.3. Where sanctions risks are identified, the relationship is terminated.
11. Refusal and Termination of Engagement
11.1. The Company reserves the right to refuse or terminate cooperation in the following cases:
11.1.1. inability to identify the client;
11.1.2. failure to provide required information;
11.1.3. suspicion of unlawful activity;
11.1.4. presence of unacceptable risks.
12. Record Keeping
12.1. The Company maintains:
12.1.1. client identification data;
12.1.2. due diligence documentation;
12.1.3. transaction records.
12.2. Retention periods are determined in accordance with applicable legislation.
12.3. Upon achievement of processing purposes or where processing is no longer necessary, data shall be deleted, destroyed, or anonymized, unless further retention is required by law.
12.4. Data may be provided to competent authorities where required.
13. Confidentiality and Data Protection
13.1. Data processing is carried out in accordance with applicable legislation, including GDPR.
13.2. Access to data is restricted to authorized persons.
13.3. Appropriate measures are implemented to prevent unauthorized access.
14. Staff Obligations
14.1. Staff are required to comply with this Policy.
14.2. Staff obligations include:
14.2.1. conducting due diligence;
14.2.2. identifying risks;
14.2.3. reporting suspicious activity.
14.3. Breach of this Policy may result in disciplinary and legal consequences.
15. Training and Awareness
15.1. The Company provides regular training to staff.
15.2. Training covers current risks, legislation, and AML practices.
16. Compliance Function
16.1. The Company maintains a compliance function.
16.2. A designated Compliance Officer is appointed, who:
16.2.1. oversees compliance with this Policy;
16.2.2. manages risks;
16.2.3. liaises with regulatory authorities.
17. Violations and Liability
17.1. Violations of this Policy are addressed in accordance with internal procedures.
17.2. Where necessary, information may be reported to competent authorities.
18. Amendments to the Policy
18.1. The Company reserves the right to amend this Policy.
18.2. Amendments become effective upon publication.
19. Contact Information
19.1. For AML and compliance-related inquiries, the Company may be contacted at: info@veritas-advisory-group.com