MONEY LAUNDERING &TERRORIST FINANCING PREVENTIONPOLICY

Money Laundering & Terrorist
Financing Prevention Policy

TABLE OF CONTENTS
SUBJECTPAGE

1.

INTRODUCTION ..................................................................................................................................................................... 3

2.

THE PURPOSE OF THIS POLICY ..................................................................................................................................... 33.

OVERVIEW OF REGULATORY FRAMEWORK........................................................................................................... 3
A.

AML/CFT Laws and Regulations .................................................................................................................... 4

B.

Beneficial Ownership (BO) Identification Laws and Regulations ............................................. 4C.

Counter-Terrorist Financing Laws and Regulations ...................................................................... 4D.

FSA Guidelines, FATF Recommendations and IOSCO Principles........................................... 5

E.

International Sanctions Regime ........................................................................................................................ 5

4.

CRIMINAL OFFENCES.......................................................................................................................................................... 55.

THE COMPANY’S ANTI MONEY LAUNDERING (AML) AND COUNTER-TERRORIST FINANCING(CTF) OBLIGATIONS ........................................................................................................................................................... 7

6.

A.

In General ...................................................................................................................................................................... 7

B.

Client Onboarding and Acceptance ............................................................................................................. 7

C.

Ongoing Client Monitoring ............................................................................................................................. 10D.

Internal and External Reporting .................................................................................................................. 10
POLICY REVIEW AND UPDATE ....................................................................................................................................... 11‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles
with company registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence,
Mahé, Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles
as a Securities Dealer with License number: SD087
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Money Laundering & Terrorist
Financing Prevention Policy

MONEY LAUNDERING & TERRORIST FINANCINGPREVENTION POLICY
1.

INTRODUCTION

1.1.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, acompany registered in Seychelles with company registration number: 8429300-1,
having its registered office at CT House, Office 9A, Providence, Mahé, Seychelles (the“Company”).

1.2.

The Company is regulated by the Financial Services Authority (‘FSA’) of Seychelles,
as a Securities Dealer with SD License number: SD087.

2.

THE PURPOSE OF THIS POLICY

2.1.

In its role as a regulated Securities Dealer, the Company is required to abide by theanti-money laundering (AML) and Counter Terrorism Financing legislation andregulations applicable in Seychelles (the “AML & CFT Laws and Regulations” - see
further below), which apply to all of its activities, and has a duty to safeguard its
customers’ money.

2.2. In line with the foregoing, the principal objective of this Policy is to provide theCompany’s (prospective) Clients with a summary of the obligations of the Company
in relation to complying with the applicable AML & CFT Laws and Regulations.
2.3. A comprehensive set of internal policies and procedures designed to assist theCompany and its officer’s, staff, agents and third party outsourced service providers
in complying with the requirements of the relevant AML & CFT Laws and Regulations
prevent the Company from being used by money launderers to further their illicit
business, is set out in the Company’s “Manual for the Prevention of Money
Laundering and Terrorist Financing”.

3.

OVERVIEW OF REGULATORY FRAMEWORK

3.1.

As a regulated Securities Dealer, the Company is, inter alia, required to comply with
the international and Seychelles laws and regulations pertaining to the preventionof money-laundering and terrorist financing, including, without limitation, thefollowing:‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles
with company registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence,
Mahé, Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles
as a Securities Dealer with License number: SD087
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Money Laundering & Terrorist
Financing Prevention Policy
A. AML/CFT Laws and Regulations
a. Anti-Money Laundering and Countering the Finance of Terrorism Act 2020;
b. Anti-Money Laundering and Countering the Finance of Terrorism Regulations
2020;
c. Anti-Money Laundering and Countering the Finance of Terrorism Regulations
2020 (1st Amendment);d. Anti-Money Laundering and Countering the Finance of Terrorism Regulations
2020 (2nd Amendment);e. Anti-Money

LaunderingandCounteringtheFinancingof

Terrorism(Amendment) Act, 2021;
f.

Anti-Money Laundering and Countering the Financing of Terrorism (Second
Amendment) Act, 2021;

g. Anti-Money Laundering and Countering(Amendment) Regulations 2022;

theFinancingof

Terrorism

h. Anti-Money Laundering and Countering the Financing of Terrorism (National
Risk Assessment) Regulations 2022;
i.

Anti-Money Laundering and Countering the Financing of Terrorism (countermeasures) Regulations 2022;

j.

Anti-Money Laundering and Countering the Financing of Terrorism (Cross
Border Declaration) Regulations 2022.

B. Beneficial Ownership (BO) Identification Laws and Regulations
a. Beneficial Ownership Act 2020;
b. Beneficial Ownership Regulation 2020;c. Beneficial Ownership (Amendment) Act, 2021.

C. Counter-Terrorist Financing Laws and Regulations
a. Prevention of Terrorism Act 2004;
b. Prevention of Terrorism (Implementation of UNSCR on Suppression ofTerrorism) Regulations 2015;c. Prevention of Terrorism (Amendment) Act, 2021;
d. Prevention of Terrorism (Second Amendment) Act 2021;
e. Prevention of Proliferation Financing Regulations, 2021;‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles
with company registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence,
Mahé, Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles
as a Securities Dealer with License number: SD087
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Money Laundering & Terrorist
Financing Prevention Policyf.

Prevention of Terrorism (Implementation of United Nations Security Council
Resolutions on Suppression of Terrorism) (Amendment) Regulations, 2022;

g. Prevention of Proliferation Financing (Amendment) Regulations, 2022;

D. FSA Guidelines, FATF Recommendations and IOSCO Principles
3.2. The above-mentioned laws and regulations are further complemented by set ofindustry guidance notes, the provisions of which the Company aims to incorporate
into its policies, procedures, and day-to-day operations; as such, in addition to theabove-mentioned laws and regulations, the Company is adhering to the following
guidance documents:
a. Representative Application Guidelines;
b. Securities Dealer Application Guidelines;
c. Financial Action Task Force (FATF) Recommendations, which are recognized
as the international standard for combating money laundering and thefinancing of terrorism and proliferation of weapons of mass destruction;d. Any other relevant legislations and general rules and principles issued by theInternational Organization of Securities Commissions (IOSCO).

E. International Sanctions Regime
3.3. Finally, there is a separate but related ‘International Sanctions Regime’ that imposes
restrictions on the Company’s ability to do business with certain persons and entities
on UN, United States (US) and European Union (EU) sanctions lists.
3.4. Some entries on these lists are specific to a particular person or entity and others are
general financial sanctions on all persons and entities in a particular jurisdiction.

4.

CRIMINAL OFFENCES

4.1.

It should be noted that, under the above-mentioned laws and regulations, a numberof different criminal offences may be committed, which are is punishable by prison
sentences and/or fines, including, without limitation:a. The offence of ‘money laundering’1, which is punishable:

1‘Money Laundering’ occurs where a person knowingly or having reasonable grounds to suspect that an asset, in whole
or in part, directly or indirectly represents proceeds of crime:a)converts or transfers that property for the purpose of concealing or disguising the illicit origin of the property
or of assisting any person who is involved in the commission of the crime to evade the legal consequences of
his action;‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles
with company registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence,
Mahé, Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles
as a Securities Dealer with License number: SD087
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Money Laundering & Terrorist
Financing Prevention Policy
(i)

(ii)

For a natural person:•with a fine not exceeding SCR 5,000,000; or•

imprisonment for a term not exceeding 15 years; or•both such fine and term of imprisonment;

For a legal entity:•

with a fine not exceeding SCR 10,000,000

b. The offence of ‘tipping off2’, which is punishable:•with a fine not exceeding SCR 200,000; or•

imprisonment for a term not exceeding six months; or•both such fine and term of imprisonment;c. The offence of ‘misrepresentation’3, which is punishable:•with a fine not exceeding SCR 200,000; or•

imprisonment for a term not exceeding six years; or•both such fine and term of imprisonment.

d. The offence of ‘malicious reporting’4, which is punishable:2•

with a fine not exceeding SCR 200,000; or•

imprisonment for a term not exceeding six years, or•both such fine and term of imprisonment.

b)conceals or disguises the true nature, source, location, disposition, movement, rights with respect to or
ownership of that property;c)acquires, possesses, uses or otherwise deals with that property; ord)participates in, associates with or conspires to commit, attempts to commit, or aids and abets, or facilitates,
counsels or procures the commission of any of the above acts.

‘Tipping off’ means informing a suspect or third party that a report of suspicion of money laundering has been madeto the FIU or to the Money Laundering Compliance Officer (hereinafter “MLCO”) or that the suspect is being investigated.

3‘Misrepresentation’ occurs when a person knowingly makes a false, fictitious or fraudulent statement or
representation, or makes, or provides, any false document, knowing the same to contain any false, fictitious or
fraudulent statement or entry, to a reporting entity, or to a supervisory authority or to the Seychelles Financial
Intelligence Unit (SFIU).

4‘Malicious Reporting’ occurs when a person willfully gives any information to the Seychelles Financial Intelligence Unit
(SFIU) or to an authorized officer, knowing such information to be false.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles
with company registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence,
Mahé, Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles
as a Securities Dealer with License number: SD087
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Money Laundering & Terrorist
Financing Prevention Policy
5.

THE COMPANY’S ANTI MONEY LAUNDERING (AML) AND COUNTERTERRORIST FINANCING (CTF) OBLIGATIONS

5.1.

It is of critical importance for the Company’s integrity and reputation that it is able
to identify, report, and take precautions to guard against money laundering andfinancing of terrorism.

5.2. The nature of the Company’s business requires it to abide by all of the abovementioned anti-money laundering (AML) and countering the financing of terrorism(CFT) legislation and regulations.

A. In General
5.3. In order to prevent the Company’s products and services from being used for thelaundering of the proceeds of crime, it is required to establish appropriate andproportionate to the level of risk, systems and controls, and ensure their effective
implementation, including, without limitation, the following:a. Identifying our Clients;
b. Identifying, monitoring and reporting any kind of suspicious transactions;c. Maintaining transaction records for a minimum of five (5) years after thetermination of our contractual relationships with our Clients;d. Training our staff to recognize suspicious transactions and to fulfil all reporting
obligations;e. Depending on Client location, report any suspicious activities to authorities inseveral countries where the Company is offering its products and services.

B. Client Onboarding and Acceptance
5.4. In line with the foregoing, the Company has established the following rules for the‘on-boarding and acceptance of Clients’:a. All Clients have to submit a valid ‘Proof of Identity (POI)’, which must be fully
legible, coloured with full name, surname and clear and identifiable
photograph; any of the following may be submitted:•

Client’s valid passport,•

Valid National Identification Card,•

Valid Driver’s License.

b. All Clients have to submit a valid ‘Proof of Residence (POR)’; POR must havebeen issued in the individual's name and must contain the individual’s‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles
with company registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence,
Mahé, Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles
as a Securities Dealer with License number: SD087
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Money Laundering & Terrorist
Financing Prevention Policy
residential address; it cannot be older than three (3) months and cannot be
the same as the document provided as proof of identity; any of the following
may be submitted:•

utility bill (electricity or water authority bill, internet or phone services bill);•bank statement (current, deposit or credit card account).

c. All Clients are screened against a ‘Risk Screening Tool Database’, in order toensure that the identity of the Client in question does not match with any
persons who are known to have criminal background or are subject tosanctions, or is associated with banned entities such as individual terrorists or
terrorist organizations, etc. In addition, the Clients are screened against
records of PEPs (including their close associates and family members), which
are also covered in the Risk Screening Tool database;d. All Clients are classified into different risk categories in line with the provisionsof the Client Classification section of the Company’s AML Manual. The following
risk factors, inter alia, are accounted for when considering the level of risk
involved with each Client relationship:•

cumulative amount of funds deposited into the Client account/accounts;•

country of residence;•nationality;•

results of risk screening, etc.

e. Depending on the level of risk assigned to the Client, additional checks may
be required for Clients, falling within higher risk categories; enhanced due
diligence is conducted for such Clients, whereby the source of funds and/or
source of wealth, and any other information deemed necessary, are verified
additionally to the checks conducted within the standard due diligence.
f.

Following the necessary checks, and based on the perceived level of risk,
associated with each Client relationship, the decision is made to either
proceed with a Client’s application or reject it. For all the Clients classified as
high-risk, an approval from either the Company’s ‘Money Laundering
Compliance Officer (MLCO)’, ‘Compliance Officer (CO)’ or ‘Chief executive
Officer (CEO)’ is required;‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles
with company registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence,
Mahé, Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles
as a Securities Dealer with License number: SD087
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Money Laundering & Terrorist
Financing Prevention Policyg. ‘Politically Exposed Persons (PEPs)’5, their family members and close
associates are classified as higher-risk and must undergo enhanced due
diligence procedures.
5.5. The screening of all Clients against the applicable UN, US and EU sanctions lists, is an
integral part of the screening of Clients against the Company’s ‘Risk Screening Tool
Database’; where a Client is identified as a true match on any of the above sanctions
list during the risk screening process, the account opening application of the Clientin question shall be rejected and no business activity shall be initiated with such
Client.
5.6. In line with the foregoing, the following are not accepted by the Company as Clients(the list below is not exhaustive):a. where sufficient KYC information could not be obtained/confirmed or as per
the Client’s risk categorization;b. the Client matches the person in the sanction lists during risk screening andthe match is confirmed to be a true match by the designated Compliance
Officer (CO) or the Money Laundering Compliance Officer (MLCO);
c. the Client matches the person in the lists with criminal records during risk
screening and the match is confirmed to be a true match by the designatedCompliance Officer (CO) or the Money Laundering Compliance Officer(MLCO);
d. Clients from countries on the list of non-cooperatives jurisdictions with the
FATF;
e. Clients from restricted jurisdictions, as per the list published on the Company’s
Website(s);f.

5Clients whose accounts are in name of companies, the shares of which are inbearer form;

The FATF's latest definition of ‘Politically Exposed Persons (PEP)’ includes the following:•

Foreign PEPs: individuals who are or have been entrusted with prominent public functions by a foreign country, forexample Heads of state or Heads of government, senior politicians, senior government, judicial or military officials,
senior executives of state-owned corporations, important political party officials.

•

Domestic PEPs: individuals who are or have been entrusted domestically with prominent public functions, forexample Heads of State or of government, senior politicians, members of parliament, senior government, judicial
or military officials, senior executives of state-owned corporations, important political party officials.

•

PEPs by function: Persons who are or have been entrusted with a prominent function by a state-owned enterpriseor an international organization refers to members of senior management, i.e. directors, deputy directors andmembers of the board or equivalent functions.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles
with company registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence,
Mahé, Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles
as a Securities Dealer with License number: SD087
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Money Laundering & Terrorist
Financing Prevention Policyg. Clients whose accounts are in name of a Trust.

C. Ongoing Client Monitoring
5.7. The ongoing monitoring of Client relationships is comprised of two sets of measures:
a. All Client records are kept up-to date, KYC information and documents are
updated regularly; these updates include, for instance, ongoing risk screening
for all existing Clients against the Company’s ‘Risk Screening Tool Database’;such Client information updates may result in re-classification of the Client
into a different risk category, in which instance, the rules for ongoing
monitoring over this Client relationship will be re-set to align with the updated
risk category;b. Ongoing screening of existing Clients against the Company’s ‘Risk Screening
Tool Database’ includes screening against the applicable UN, US and EU
sanctions lists; in the event that a Client is identified as a true match on any of
the above sanctions lists during the ongoing risk screening process, theaccount of the Client shall be closed and no further business activity shall be
conducted with such Client;c. The Company’s transaction monitoring rules are designed in accordance withthe applicable risk classification of a Client relationship; ongoing monitoringof each Client’s activity is conducted by the Company’s Compliance Officers
and Money Laundering Compliance Officers, in “real-time” andretrospectively.

D. Internal and External Reporting
5.8. Clients should assume that all information provided to the Company is available tothe competent regulatory authorities in (a) the country of incorporation of theCompany, i.e. the Republic of Seychelles; (b) the country of origin of any funds
transmitted to the Company; and (c) the destination country of any funds refundedby or withdrawn from the Company.
5.9. The Company reserves the right to refuse the processing of a transfer of funds at any
stage if it believes it to be connected in any way to criminal activities or money
laundering.
5.10. The Company is obliged to report all suspicious transactions and is prohibited frominforming Clients in case they have been reported for suspicious account activity.
5.11. As indicated above, any such misuse of an account held with the Company formoney laundering, terrorist financing and/or related offences that is reported to therelevant authorities may result in criminal prosecution.
‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles
with company registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence,
Mahé, Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles
as a Securities Dealer with License number: SD087
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Money Laundering & Terrorist
Financing Prevention Policy
6.

POLICY REVIEW AND UPDATE

6.1.

The Company reserves the right to review and/or amend its Money Laundering
Prevention Policy, in its sole discretion, whenever it deems fit or appropriate.

6.2. Should you have a question about our Money Laundering Prevention Policy please
direct your questions to our Compliance Department: compliance@finpros.com.

____________________________‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles
with company registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence,
Mahé, Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles
as a Securities Dealer with License number: SD087
Page 11 of 11