AML/KYC POLICY
LTG Goldrock Limited Ltd Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of LTG Goldrock Limited Ltd being involved in any kind of illegal activity.
Both international and local regulations require LTG Goldrock Limited Ltd to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, the proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.
AML/KYC Policy covers the following matters:- Verification procedures
- Sanctions and PEP lists screening.
- Compliance Officer.
- Monitoring Transactions.
- Risk Assessment.
- VERIFICATION PROCEDURESOne of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, LTG Goldrock Limited Ltd establishes its verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.
- Identity verificationLTG Goldrock Limited Ltd ‘s identity verification procedure requires the User to provide LTG Goldrock Limited Ltd with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes, LTG Goldrock Limited Ltd reserves the right to collect User’s identification information for the AML/KYC Policy purposes.LTG Goldrock Limited Ltd will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and LTG Goldrock Limited Ltd reserves the right to investigate certain Users who have been determined to be risky or suspicious.LTG Goldrock Limited Ltd reserves the right to verify User’s identity on an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). Besides, LTG Goldrock Limited Ltd reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.User’s identification information will be collected, stored, shared and protected strictly following the LTG Goldrock Limited Ltd ‘s Privacy Policy and related regulations.Once the User’s identity has been verified, LTG Goldrock Limited Ltd can remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
- Card verificationThe Users who are intended to use payment cards in connection with the LTG Goldrock Limited Ltd Services have to pass card verification following instructions available on the LTG Goldrock Limited Ltd Site.
- SANCTIONS AND PEP LISTS SCREENING.LTG Goldrock Limited Ltd screens applicants against recognised Sanctions and Politically Exposed Persons (PEPs) lists. Individuals and legal entities are screened against mentioned lists:
- on the onboarding stage when the user is applying;
- on each anti-fraud and AML alerts manually by Compliance Officer;
- monthly by running automatically with a script to re-check all DB of customers.
For the screening process performing LTG Goldrock Limited Ltd uses World Compliance data (provided by LexisNexis) integrated into the proprietary software and supported by World-Check One online search tool (provided by Refinitiv) for manual confirmation. - COMPLIANCE OFFICERThe Compliance Officer is the person, duly authorized by LTG Goldrock Limited Ltd, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of LTG Goldrock Limited Ltd’s anti-money laundering and counter-terrorist financing, including but not limited to: a. Collecting Users’ identification information. b. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations. c. Monitoring transactions and investigating any significant deviations from normal activity. d. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs. e. Updating risk assessment regularly. f. Providing law enforcement with information as required under the applicable laws and regulations.The Compliance Officer is entitled to interact with law enforcement, which is involved in the prevention of money laundering, terrorist financing and other illegal activity.
- MONITORING TRANSACTIONSThe Users are known not only by verifying their identity (who they are) but, more importantly, by analysing their transactional patterns (what they do). Therefore, LTG Goldrock Limited Ltd relies on data analysis as a risk-assessment and suspicion detection tool. LTG Goldrock Limited Ltd performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:1. Daily check of Users against recognized “blacklists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;2. Case and document management.The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
- ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
- request the User to provide any additional information and documents in case of suspicious transactions;
- suspend or terminate User’s Account when LTG Goldrock Limited Ltd has reasonable suspicion that such User engaged in illegal activity.
Concerning the AML/KYC Policy, LTG Goldrock Limited Ltd will monitor all transactions and it reserves the right to: - RISK ASSESSMENTLTG Goldrock Limited Ltd, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, LTG Goldrock Limited Ltd can ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed following priorities so that the greatest risks receive the highest attention.
REFUND POLICY
Refund Policy has been developed to reduce financial and legal risks of the Company, observe principles of anti-money laundering and counter terrorist financing policy. The Company has the right to unilaterally block the access to the Client area, suspend trading activity of Accounts, cancel a request for transfer/ withdrawal, or make a refund, if the source of funds or the Client’s activities contradict the anti-money laundering and counter terrorist financing policy.
The Company does not cancel the implemented trade transactions, therefore the Company has the right to return the funds to the remitter, if within one month from the date of recharge, no trading activity has been recorded on the trading accounts.
The Company has the right, under certain objective reasons and, if it is necessary, to make a refund of funds received via any payment system including credit/debit cards. Furthermore, the refund will be made to electronic wallets and bank details, which have been used by the Client when paying in the funds. It should also be mentioned that withdrawal of the total deposit amount is only possible on the same requisites and to the same payment system that were used during depositing the account.
The timescales for funds withdrawal do not exceed two banking days from the moment of sending the funds withdrawal request. In some cases, money transfers can exceed the stated timescales depending on a payment system/ an emitting bank.
If the Company classifies the activities of the Client as inappropriate or contradicting the usual purpose of the Company’s services usage, where there is a direct, or indirect, illegal or dishonest intent, the Company has the right to act within the framework of this document, without informing the Client in advance. All direct or indirect losses; expenses connected with transfer of funds are reimbursed to the Company from the Client’s funds.
When replenishing a trade account with a credit card, the Client agrees not to lodge a request to the bank to charge the payment back, which has already been received to the trade account or to the provider of a credit/debit bank card, both during and after the use of the Company’s services. Any such attempt will be treated by the Company as a breach of the Contract for the provision of services, for which the Client may be subjected to responsibility in accordance with national legislation.
The Company will take all necessary measures to prevent and block both crediting and withdrawal of funds from the Client’s account by third parties. Crediting and withdrawal of funds from the account can be performed only be the holder of this account.
Company: «LTG Goldrock Limited.» No. 1 Corner of Hutson Street and Marine Parade, Belize City, Belize