AML CTF Policy

Introduction

Purpose

This anti-money Laundering and Counter-Terrorism Financing Policy outlines Avnato’s commitment to preventing the use of our e-commerce platform for money laundering and terrorist financing activities. This policy aims to ensure compliance with relevant legal and regulatory requirements and safeguard the integrity of our platform, thereby protecting our customers, stakeholders, and the broader community.

Scope

This AML CTF Policy applies to all employees, officers, directors, contractors, consultants, and agents of Avnato, owned by Rollion Sp. z o.o., registered at street Hoża, No. 86, Apt/Room 210, 00-682, Warsaw, Poland; registration number:.527865284. It covers all business activities and operations conducted through the Avnato e-commerce platform, including but not limited to customer transactions, financial operations, and any other activities that could potentially be exploited for money laundering or terrorist financing.

Definitions

Money Laundering: Disguising the origins of illegally obtained money, typically using transfers involving foreign banks or legitimate businesses.
Terrorist Financing: Providing financial support to individual terrorists or terrorist groups.
Customer Due Diligence: The process of identifying and verifying the identity of customers and understanding the nature of their transactions to prevent money laundering and terrorist financing.
Enhanced Due Diligence: Additional scrutiny applied to high-risk customers and transactions to mitigate the risk of money laundering and terrorist financing.
Suspicious Activity Report): A report filed by financial institutions to notify authorities of suspicious transactions that may involve money laundering or terrorist financing.

Relevant Legislation

Avnato, as an e-commerce platform operated by Rollion Sp. z o.o. is committed to complying with the following relevant AML and CTF legislation and regulations:

Polish Act on Counteracting Money Laundering and Terrorist Financing (AML Act): This Act governs the measures to be taken to prevent and combat money laundering and terrorist financing within Poland.
European Union Anti-Money Laundering Directives: These directives establish the framework for AML regulations across EU member states, including customer due diligence, reporting obligations, and record-keeping requirements.
Financial Action Task Force Recommendations: The FATF provides international standards for combating money laundering and terrorist financing, which Avnato adheres to as part of its global compliance efforts.

By adhering to these laws and regulations, Avnato ensures that it remains vigilant in the fight against money laundering and terrorist financing, thereby maintaining its customers’ and stakeholders’ trust and confidence.

Company Commitment

Statement of Commitment

Avnato, owned by Rollion Sp. z o.o. is fully committed to preventing its e-commerce platform from being used for money laundering and terrorist financing activities. We uphold the highest standards of integrity and transparency in our operations, ensuring compliance with all relevant laws and regulations. Our dedication to combating financial crime is central to our business operations, reflecting our responsibility to our customers, stakeholders, and the broader community.

Responsibilities of the Board and Management

The Board of Directors and Management of Avnato are committed to the effective implementation and ongoing oversight of the company’s AML and CTF policies and procedures. Their responsibilities include:

Governance and Oversight: The Board and senior management are responsible for establishing, approving, and maintaining the AML CTF Policy. They ensure that adequate resources are allocated for its effective implementation.
Policy Development and Review: The Board oversees the development, periodic review, and continuous improvement of the AML CTF Policy to ensure it remains current with legal requirements and industry best practices.
Risk Assessment: Management is responsible for conducting regular risk assessments to identify potential money laundering and terrorist financing risks associated with Avnato’s operations and implementing appropriate mitigating controls.
Compliance Officer: The Board appoints a designated AML Compliance Officer with the authority and responsibility to oversee the daily operations of the AML CTF program. The AMLCO reports directly to the Board.
Training and Awareness: The Board and management ensure that all employees, particularly those in high-risk areas, receive ongoing training on AML and CTF regulations, internal policies, and procedures. This training aims to raise awareness and ensure staff can identify and respond to potential money laundering and terrorist financing activities.
Monitoring and Reporting: Management ensures the establishment of robust systems for ongoing monitoring of transactions and activities, ensuring suspicious activities are detected and reported in compliance with regulatory requirements. Regular reports on the effectiveness of the AML CTF program are provided to the Board.
Internal Controls and Audits: The Board and management are responsible for implementing adequate internal controls and procedures to ensure compliance with the AML CTF Policy. Regular independent audits are conducted to assess the adequacy and effectiveness of the AML CTF program.
Accountability and Enforcement: The Board and management enforce accountability for AML CTF compliance across the organisation. Any breaches of the policy are taken seriously, and appropriate disciplinary actions are taken against those found in violation.

By fulfilling these responsibilities, the Avnato board and Management demonstrate their commitment to maintaining a robust AML CTF framework, ensuring the integrity of our e-commerce platform, and protecting it from being exploited for illicit activities.

Risk Assessment

Risk Identification

Avnato, through its parent company Rollion Sp. z o.o. undertakes a comprehensive approach to identifying potential money laundering and terrorist financing risks associated with its e-commerce platform. The identification process includes:

Customer Risk: Assessing the risk profiles of customers based on factors such as geographic location, business activities, and transaction patterns.
Product/Service Risk: Evaluating the risk associated with the products and services offered on the platform, including high-value goods, digital services, and other items that may be more susceptible to ML/TF activities.
Transaction Risk: Monitoring transaction types and sizes, identifying unusual or suspicious activities that may indicate potential ML/TF risks.
Geographical Risk: Identifying and assessing the risks associated with customers or transactions involving countries or regions with higher incidences of ML/TF, weak regulatory oversight, or significant criminal activity.
Channel Risk: Considering the risks associated with different delivery channels, including online transactions, third-party payment processors, and cross-border payments.

Risk Analysis and Evaluation

Once potential ML/TF risks are identified, Avnato evaluates and analyses them to determine their significance and impact on the organisation. This involves:

Risk Assessment Matrix: Utilising a risk assessment matrix to categorise risks based on their likelihood and potential impact. Risks are classified as low, medium, or high.
Data Analysis: Analysing transaction data, customer information, and other relevant metrics to identify patterns and trends that may indicate higher risks.
Scenario Analysis: Conducting scenario analysis to understand the potential consequences of identified risks and how they might affect the business operations.
Compliance Reviews: Regularly reviewing compliance with AML/CTF regulations and assessing the effectiveness of existing controls in mitigating identified risks.
Stakeholder Input: Engaging with relevant stakeholders, including legal advisors, industry experts, and regulatory bodies, to gain insights into emerging risks and best practices for risk management.

Risk Mitigation

Avnato implements risk mitigation strategies to address identified ML/TF risks effectively. These strategies include:

Enhanced Due Diligence: Applying EDD measures for higher-risk customers, transactions, and jurisdictions. This includes collecting additional information and conducting thorough background checks.
Transaction Monitoring: Implementing advanced transaction monitoring systems to detect and flag suspicious activities in real time. Regular audits and reviews of transaction data are conducted to ensure the effectiveness of these systems.
Customer Verification: Strengthening customer identification and verification processes, including Know Your Customer procedures, to ensure the accuracy and reliability of customer information.
Employee Training: Providing ongoing training on AML/CTF policies, procedures, and emerging risks. Ensuring staff can identify and respond to potential ML/TF activities.
Reporting Mechanisms: Establish clear reporting mechanisms for suspicious activities, ensure that employees are aware of their obligations to report suspicious transactions, and provide a secure and confidential channel for reporting.
Policy and Procedure Updates: Regularly updating AML/CTF policies and procedures to reflect changes in regulatory requirements, industry standards, and emerging risks.
Collaborative Efforts: Collaborating with other e-commerce platforms, financial institutions, and regulatory bodies to share information and best practices for mitigating ML/TF risks.

By systematically identifying, analysing, and mitigating ML/TF risks, Avnato maintains a robust and compliant AML/CTF framework, safeguarding the integrity of its e-commerce platform and protecting its customers and stakeholders from illicit activities.

Customer Due Diligence

Customer Identification and Verification

Avnato is committed to ensuring that its customers’ identities are accurately established and verified. This process is fundamental in preventing money laundering and terrorist financing activities on our platform.

Identification Procedures:

Individual Customers: For individual customers, Avnato collects basic personal information, including full name, date of birth, residential address, and nationality. Identification documents such as passports, national ID cards, or driver’s licenses are required for verification.
Corporate Customers: For corporate customers, we collect information about the entity, such as the business name, registration number, registered address, and the identities of key individuals (e.g., directors and beneficial owners). Verification involves obtaining and verifying documents such as certificates of incorporation, company bylaws, and identification of directors and shareholders.

Verification Methods:

Documentary Verification: Reviewing and verifying government-issued identification documents and, for corporate customers, reviewing official business documents.
Electronic Verification: Utilising electronic verification systems that cross-check customer information against public records and databases.
Face-to-Face Verification: Where possible, conduct face-to-face verification in person or via secure video conferencing.

Ongoing Monitoring

Avnato recognizes that customers’ risk profiles can change over time. Therefore, continuous monitoring is essential to ensure ongoing compliance with AML/CTF regulations.

Monitoring Activities:

Transaction Monitoring: Implementing systems to monitor transactions for unusual or suspicious activities. This includes setting transaction limits and alert thresholds to flag potentially suspicious behaviour.
Customer Activity Review: Periodically reviewing customer activities to ensure consistency with their known profile and business activities. This includes re-evaluating the risk rating of customers based on their transaction patterns.
Updating Customer Information: Ensuring that customer information is up-to-date. Customers may be required to provide updated information periodically or whenever significant changes in their profile are detected.

Suspicious Activity Reporting:

Internal Reporting: Employees are trained to identify and report suspicious activities to the designated AML/CTF compliance officer.
External Reporting: Suspicious activities are reported to relevant regulatory authorities by legal requirements.

Enhanced Due Diligence

Enhanced Due Diligence measures are applied to higher-risk customers and transactions. These measures provide greater scrutiny to mitigate the increased risks associated with these customers or activities.

High-Risk Indicators:

Customers from high-risk jurisdictions or countries with high corruption or criminal activity levels.
Politically Exposed Persons or individuals with significant public functions.
Complex or huge transactions that do not match the customer’s known profile.
Transactions involving high-risk products or services.

EDD Measures:

Additional Information Collection: Gathering more detailed information about the customer’s source of funds, purpose of transactions, and the nature of their business.
Increased Monitoring: Implementing more frequent and detailed monitoring of transactions and activities for high-risk customers.
Senior Management Approval: Requiring approval from senior management before establishing or continuing business relationships with high-risk customers.
Enhanced Verification: Conducting additional verification checks and utilising more robust verification methods for high-risk customers.

By implementing these Customer Due Diligence procedures, including stringent identification and verification processes, continuous monitoring, and Enhanced Due Diligence for high-risk scenarios, Avnato aims to effectively mitigate the risks associated with money laundering and terrorist financing, ensuring a secure and compliant platform for all its users.

Reporting Obligations

Suspicious Activity Reporting

Avnato is committed to identifying and reporting suspicious activities that may indicate money laundering or terrorist financing. This process is critical for maintaining the integrity of our e-commerce platform and complying with legal obligations.

Identification of Suspicious Activities:

Transaction Red Flags: Unusual transaction patterns include large, frequent transactions inconsistent with the customer’s known profile, multiple small transactions that add up to a large amount, and transactions with no apparent economic or lawful purpose.
Behavioral Red Flags: Customers who are unwilling or unable to provide necessary information for verification, provide false or misleading information, or exhibit unusual behaviour during the verification process.
Geographic Red Flags: Transactions involving countries or regions identified as high-risk for money laundering or terrorist financing.

Internal Reporting Process:

Employee Training: Employees are trained to recognize and report suspicious activities promptly.
Reporting Mechanism: Employees report suspicious activities to the designated AML/CTF Compliance Officer using an internal reporting form.
Compliance Officer Review: The Compliance Officer reviews the reported activity, conducts further investigation if necessary, and determines whether the activity warrants a SAR.

External Reporting:

Regulatory Authorities: If the Compliance Officer deems the activity suspicious, a SAR is filed with the appropriate regulatory authorities by legal requirements. This includes providing detailed information about the suspicious activity and relevant customer information.
Confidentiality: All SAR filings are kept confidential, and the customer involved is not notified of the report.

Currency Transaction Reporting

Avnato must report large currency transactions that meet or exceed certain thresholds. These reports help regulatory authorities monitor and track potential money laundering and terrorist financing activities.

Thresholds and Requirements:

Threshold Amount: Transactions involving the transfer of currency amounts equal to or exceeding the legally mandated threshold.
Aggregation of Transactions: Multiple transactions conducted by or on behalf of the same customer within a 24-hour period that collectively meet or exceed the threshold must be reported.

Reporting Process:

Transaction Monitoring: Systems are in place to monitor and flag transactions that meet or exceed the reporting threshold.
Information Collection: Detailed information about the customer and the transaction, including the amount, date, and nature of the transaction, is collected.
Filing CTR: The Compliance Officer files a CTR with the relevant regulatory authorities, providing all required information.

Record Keeping and Retention

Avnato maintains comprehensive records of all transactions, customer information, and reports related to AML/CTF compliance. This ensures transparency, accountability, and the ability to respond to regulatory inquiries.

Record Keeping Requirements:

Transaction Records: Detailed records of all transactions, including dates, amounts, types of transactions, and customer information.
Customer Identification Records: Copies of identification documents, verification records, and any additional information collected during the customer due diligence.
SAR and CTR Records: Copies of all Suspicious Activity Reports (SARs) and Currency Transaction Reports filed, along with supporting documentation and internal investigation records.

Retention Period:

Minimum Retention Period: All records are retained for a minimum period of five years from the date of the transaction or the end of the customer relationship, whichever is later.
Extended Retention: Records may be retained for longer periods if required by law or if they are relevant to ongoing investigations or litigation.

Access and Security:

Restricted Access: Access to records is restricted to authorised personnel only.
Data Security: Records are stored securely, with appropriate measures to prevent unauthorised access, alteration, or destruction.

By adhering to these reporting obligations, including prompt and accurate reporting of suspicious activities and large currency transactions and maintaining thorough records, Avnato ensures compliance with AML/CTF regulations and contributes to the global effort to combat financial crime.

Internal Controls and Procedures

Effective internal controls and procedures are essential for Avnato to prevent and detect money laundering and terrorist financing activities. These controls ensure compliance with relevant legislation and regulatory requirements, promoting a culture of integrity and responsibility within the organisation.

Internal Policies and Procedures

Avnato has developed comprehensive internal policies and procedures to guide employees in identifying, preventing, and reporting potential money laundering and terrorist financing activities. These policies and procedures are regularly reviewed and updated to reflect changes in regulations and emerging risks.

Key Policies and Procedures:

AML/CTF Policy: Outlines Avnato’s commitment to combating money laundering and terrorist financing, detailing the responsibilities of employees and management.
Customer Due Diligence Procedures: Describes the processes for verifying customer identities, conducting risk assessments, and performing ongoing monitoring.
Suspicious Activity Reporting Procedures: This section provides guidelines for identifying and reporting suspicious activities, including the internal reporting process and the role of the Compliance Officer.
Currency Transaction Reporting Procedures: Details the requirements for monitoring and reporting large currency transactions, including aggregating multiple transactions.
Record Keeping and Retention Policy: This policy specifies the types of records to be maintained, retention periods, and procedures for ensuring the security and confidentiality of records.

Transaction Monitoring Systems

Avnato employs advanced transaction monitoring systems to detect unusual or suspicious activity that may indicate money laundering or terrorist financing. These systems use automated processes to analyse transactions and identify patterns or anomalies that warrant further investigation.

Key Features of Transaction Monitoring Systems:

Automated Alerts: The system generates alerts for transactions that meet predefined criteria or exhibit unusual patterns, such as large, frequent transactions or transactions involving high-risk countries.
Risk-Based Analysis: Transactions are analysed based on the customer’s risk profile, transaction history, and other relevant factors to identify potential risks.
Investigation and Escalation: Alerts are reviewed by trained personnel, who conduct further investigations and escalate cases to the Compliance Officer if necessary.
Reporting Capabilities: The system supports the generation of reports required for regulatory compliance, such as SARs and CTRs, ensuring timely and accurate filing with the relevant authorities.

Employee Training Programs

Ongoing training ensures all employees understand their roles and responsibilities in preventing money laundering and terrorist financing. Avnato provides comprehensive training programs to equip employees with the knowledge and skills to recognize and respond to potential risks.

Key Components of Employee Training Programs:

Mandatory Training: All employees must complete AML/CTF training upon joining the company and at regular intervals. Training covers the basics of money laundering and terrorist financing, relevant legislation, and Avnato’s internal policies and procedures.
Role-Specific Training: Employees in high-risk roles, such as customer service, compliance, and finance, receive additional training tailored to their specific responsibilities and the risks they may encounter.
Case Studies and Scenarios: Training includes real-life case studies and scenarios to help employees understand how to identify suspicious activities and apply AML/CTF policies in practice.
Ongoing Education: Regular updates and refresher courses inform employees about new threats, regulatory changes, and best practices in AML/CTF compliance.
Evaluation and Feedback: Training effectiveness is evaluated through assessments and participant feedback, allowing for continuous improvement of the training programs.

By implementing robust internal controls and procedures, including detailed policies, advanced transaction monitoring systems, and comprehensive employee training programs, Avnato ensures a proactive approach to AML/CTF compliance and protects the organisation and its stakeholders from financial crime.

Compliance Officer

The Compliance Officer’s role is pivotal in ensuring that Avnato adheres to its Anti-Money Laundering and Counter-Terrorist Financing obligations. The Officer is responsible for implementing and overseeing the company’s AML/CTF policies and procedures, ensuring that the organisation remains compliant with all relevant regulations.

Appointment and Role

Appointment:

The Compliance Officer is appointed by the Board of Directors of Rollion Sp. z o.o., the parent company of Avnato.
The appointment is based on the individual’s expertise in AML/CTF regulations, experience in the financial services industry, and ability to oversee compliance programs effectively.

Role:

The Compliance Officer is the primary point of contact between Avnato and regulatory authorities regarding AML/CTF matters.
The officer is responsible for ensuring that Avnato’s AML/CTF program is effectively managed and compliant with current laws and regulations.

Duties and Responsibilities

Development and Implementation:

Develop, implement, and maintain Avnato’s AML/CTF policies and procedures.
Ensure these policies align with local and international regulations and best practices.
Regularly review and update policies to address new risks and regulatory changes.

Training and Awareness:

Design and oversee AML/CTF training programs for all employees, ensuring staff members know their roles in preventing money laundering and terrorist financing.
Provide ongoing training and updates to reflect changes in legislation and emerging risks.

Monitoring and Reporting:

Monitor transactions and activities to detect suspicious behaviour that may indicate money laundering or terrorist financing.
Oversee transaction monitoring systems and ensure that alerts are investigated promptly and thoroughly.
Prepare and file Suspicious Activity Reports and Currency Transaction Reports as the law requires.
Maintain records of all reports and ensure that they are filed promptly.

Risk Assessment:

Conduct regular risk assessments to identify and mitigate potential money laundering and terrorist financing risks.
Develop strategies to address identified risks and ensure they are implemented effectively.
Collaborate with other departments to integrate AML/CTF risk management into the company’s overall risk management framework.

Internal Audits and Reviews:

Conduct regular internal audits of AML/CTF policies, procedures, and controls to ensure effectiveness.
Report findings to the Board of Directors and recommend corrective actions where necessary.
Ensure that any deficiencies identified during audits are addressed promptly.

Regulatory Liaison:

Serve as the primary contact for regulatory authorities on AML/CTF matters.
Ensure timely and accurate reporting to regulatory bodies as required.
Stay informed about regulatory changes and ensure Avnato’s policies and procedures remain compliant.

Advisory Role:

Advise the Board of Directors and senior management on AML/CTF compliance issues and best practices.
Guide on complex AML/CTF matters and support decision-making processes.

Record Keeping:

Ensure that all records related to AML/CTF activities, including customer due diligence documents, transaction records, and training logs, are maintained accurately and securely.
Comply with legal and regulatory requirements for the retention of records.

By appointing a dedicated Compliance Officer with clearly defined duties and responsibilities, Avnato demonstrates its commitment to maintaining a robust AML/CTF compliance program, protecting the organisation and its stakeholders from financial crime, and ensuring adherence to all relevant regulations.

Communication and Training

Effective communication and training are critical to Avnato’s AML/CTF compliance program. These elements ensure that all employees know their responsibilities, understand the company’s policies and procedures, and are equipped to identify and respond to potential money laundering and terrorist financing activities.

Training Programs

Initial Training:

Regardless of their role, all new employees must complete AML/CTF training as part of their onboarding process.
Initial training covers the basics of AML/CTF regulations, Avnato’s policies and procedures, and the employees’ roles and responsibilities in preventing financial crime.

Ongoing Training:

Regular, ongoing training sessions are provided to all employees to inform them about changes in AML/CTF regulations and updates to company policies.
Training materials are updated frequently to reflect current trends, emerging risks, and best practices in AML/CTF compliance.

Specialised Training:

Employees in high-risk roles or departments (e.g., finance, customer service, compliance) receive specialised training tailored to their specific responsibilities.
This training includes detailed information on detecting suspicious activities, conducting due diligence, and the proper procedures for reporting suspicious transactions.

Training Delivery Methods:

Training is delivered through various methods, including in-person workshops, online courses, webinars, and interactive training modules.
Training effectiveness is evaluated through assessments, quizzes, and feedback surveys to ensure comprehension and engagement.

Communication Strategies

Regular Updates:

Employees receive regular AML/CTF topic updates through newsletters, email bulletins, and intranet postings.
These updates include information on regulatory changes, internal policy updates, and relevant case studies or examples.

Clear Policies and Procedures:

All AML/CTF policies and procedures are documented clearly and made accessible to all employees.
The Compliance Officer ensures that any changes to policies or procedures are communicated promptly and clearly.

Open Communication Channels:

Avnato fosters an open communication environment where employees feel comfortable reporting suspicious activities or asking questions about AML/CTF issues.
Dedicated communication channels, such as a compliance hotline or email address, allow employees to report concerns confidentially.

Management Engagement:

Senior management regularly communicates the importance of AML/CTF compliance, reinforcing the company’s commitment and the critical role employees play in maintaining compliance.
Management participates in training sessions and leads by example, demonstrating their support for AML/CTF initiatives.

Employee Responsibilities

Understanding and Compliance:

Employees must understand and comply with Avnato’s AML/CTF policies and procedures.
They must stay informed about regulatory changes and updates to internal policies.

Vigilance and Reporting:

Employees are expected to be vigilant in identifying potential money laundering or terrorist financing activities.
They must report any suspicious activities immediately to the Compliance Officer or through the designated reporting channels.

Participation in Training:

All employees must participate in mandatory AML/CTF training programs and complete any required assessments.
Employees are encouraged to provide feedback on training programs to help improve their effectiveness.

Cooperation with Compliance Efforts:

Employees must cooperate fully with the Compliance Officer and other relevant personnel in implementing and maintaining AML/CTF controls.
They are expected to assist in audits, risk assessments, and other compliance-related activities.

By establishing comprehensive communication and training programs, Avnato ensures that all employees are well-informed, equipped to fulfil their AML/CTF compliance roles, and actively engaged in maintaining the integrity and security of the company’s operations.

Record Keeping

Effective record-keeping is essential to Avnato’s AML/CTF compliance program. It ensures that all necessary information is documented and retained to support compliance efforts, facilitate audits, and provide evidence of due diligence in the event of regulatory scrutiny.

Types of Records to be Maintained

Customer Identification Records:

Copies of documents used to verify the identity of customers, including passports, driver’s licence, and utility bills.
Records of information collected during Customer Due Diligence and Enhanced Due Diligence processes, such as customer name, address, date of birth, and nature of business.

Transaction Records:

Detailed records of all customer transactions, including date, amount, currency, and parties involved.
Documentation of the purpose and nature of transactions, especially for high-value or suspicious transactions.

Suspicious Activity Reports:

Copies of all SARs filed with relevant authorities, including the rationale for filing and supporting documentation.
Internal records of investigations conducted before filing SARs.

Training Records:

Documentation of AML/CTF training programs, including attendance logs, training materials, and assessment results.
Records of employee acknowledgments of AML/CTF policies and procedures.

Compliance and Audit Records:

Records of internal and external AML/CTF compliance audits, including audit reports and management responses.
Documentation of compliance reviews, risk assessments, and any remedial actions taken.

Correspondence with Regulatory Authorities:

Copies of all correspondence with regulatory authorities related to AML/CTF compliance, including responses to inquiries and notifications of policy changes.

Record Retention Periods

Standard Retention Period:

All records related to AML/CTF compliance must be retained for a minimum of five years from the date of the transaction or the end of the customer relationship, whichever is later.

Extended Retention Periods:

If a record is subject to an ongoing investigation, legal proceedings, or regulatory review, it must be retained until the matter is resolved and confirmation is received that the record can be destroyed.

Destruction of Records:

After the retention period has expired, records must be securely destroyed in a manner that prevents their reconstruction or retrieval.

Methods of Record Keeping

Digital Records:

Records are primarily maintained in digital format using secure, encrypted systems to ensure data integrity and accessibility.
Digital records must be backed up regularly and stored in compliance with data protection regulations.

Physical Records:

Physical records, if maintained, must be stored in secure locations with restricted access to authorised personnel only.
Physical records must be scanned and digitised to facilitate efficient storage and retrieval.

Access Controls:

Access to records is restricted based on role and responsibility to ensure that only authorised personnel can view or modify sensitive information.
Audit trails are maintained to track access and changes to records.

Data Protection:

All digital or physical records must be protected against unauthorised access, loss, or alteration through robust security measures, including encryption, firewalls, and secure storage facilities.
Regular audits are conducted to ensure compliance with record-keeping policies and identify and address potential vulnerabilities.

Regular Review and Update:

Record-keeping practices are regularly reviewed and updated to ensure compliance with evolving regulatory requirements and industry best practices.
Employees are trained on the importance of accurate and timely record-keeping as part of the overall AML/CTF compliance program.

By adhering to these record-keeping guidelines, Avnato ensures that all necessary information is documented and retained to support AML/CTF compliance efforts, facilitate audits, and provide evidence of due diligence in the event of regulatory scrutiny.

Monitoring and Review

Monitoring and review processes are integral to Avnato’s Anti-Money Laundering and Counter-Terrorist Financing compliance framework. These processes ensure that our policies, procedures, and controls remain effective and compliant with regulatory requirements and industry standards.

Regular Audits and Reviews

Internal Audits:

Avnato conducts regular internal audits of its AML/CTF policies, procedures, and controls to assess their effectiveness and identify areas for improvement.
Audits are performed by independent personnel or a designated compliance team to maintain objectivity and thoroughness.
Audit findings are documented, and corrective actions are promptly implemented to address identified deficiencies.

External Audits:

Avnato periodically engages external auditors or consultants with AML/CTF compliance expertise to conduct independent reviews of our operations.
External audits provide an unbiased assessment of our compliance program’s effectiveness and adherence to regulatory standards.
Recommendations from external audits are carefully considered and integrated into our compliance framework as appropriate.

Continuous Improvement

Feedback Mechanisms:

Avnato encourages feedback from employees, customers, regulatory authorities, and other stakeholders regarding our AML/CTF compliance practices.
Feedback is carefully reviewed and considered for potential enhancements to our policies, procedures, and controls.

Risk-Based Approach:

Our monitoring and review processes are guided by a risk-based approach, focusing resources on areas of higher risk to ensure robust mitigation strategies are in place.
Risks identified through monitoring and review activities are promptly assessed, and mitigation measures are adjusted accordingly.

Updating the Policy

Policy Review Cycle:

The AML/CTF policy is reviewed annually or more frequently to reflect changes in regulatory requirements, industry practices, or internal operations.
Updates to the policy are communicated to all relevant employees and stakeholders to ensure awareness and compliance with revised procedures.

Documentation and Version Control:

Revised AML/CTF policy versions are documented with a precise “Last Updated” date to distinguish them from previous versions.
Previous policy versions are archived to reference and demonstrate historical compliance efforts.

Commitment to Compliance

Avnato is committed to maintaining a proactive approach to AML/CTF compliance through robust monitoring, regular audits, continuous improvement initiatives, and timely updates to our policies and procedures. Adhering to these practices ensures that our operations remain secure, transparent, and aligned with regulatory expectations.

Penalties for Non-Compliance

Avnato takes non-compliance with Anti-Money Laundering and Counter-Terrorist Financing regulations seriously and imposes strict penalties to deter and address violations. Non-compliance may result in both internal disciplinary actions and legal consequences.

Internal Disciplinary Actions

Employee Accountability:

Employees who breach AML/CTF policies, procedures, or regulations may face disciplinary measures, including verbal or written warnings, suspension, demotion, or termination of employment.
Disciplinary actions are commensurate with the severity and recurrence of the violation and are implemented by Avnato’s internal policies and employment contracts.

Responsibility of Management:

Management and supervisory personnel are accountable for ensuring adherence to AML/CTF requirements within their respective teams and departments.
Failure to fulfil supervisory responsibilities or address compliance deficiencies promptly may result in managerial sanctions or disciplinary actions.

Legal Consequences

Regulatory Enforcement:

Non-compliance with AML/CTF regulations may lead to regulatory enforcement actions, including fines, sanctions, or restrictions imposed by relevant authorities.
Avnato cooperates fully with regulatory investigations and audits, providing necessary documentation and transparency to demonstrate compliance efforts.

Legal Liabilities:

Individuals involved in money laundering, terrorist financing, or related criminal activities may face legal liabilities, including criminal prosecution, imprisonment, and financial penalties.
Avnato supports law enforcement agencies in prosecuting illicit activities detected through our AML/CTF monitoring and reporting mechanisms.

Compliance Culture

Avnato promotes a culture of compliance through comprehensive training, regular audits, and proactive monitoring to prevent, detect, and mitigate risks associated with money laundering and terrorist financing. By enforcing penalties for non-compliance internally and under legal frameworks, we uphold our commitment to integrity, transparency, and regulatory compliance across all operations.

Contact Us

For questions regarding this policy, please get in touch with us: