ANTI-MONEY LAUNDERING POLICY

Money laundering is the act of converting money or other monetary instruments gained from illegal activity into money or investments that appear to be legitimate so that its illegal source cannot be traced. It is known that persons involved in Money laundering use forged documents of identification and false information for the purpose of money laundering activities through banking institutions. Thus, the main principle that underlies all other actions related to prevention of Money laundering and financing of terrorism is establishment of the identity of System customers and carrying out the «Know Your Customer» procedures.

IMPLEMENTED PROCEDURES
The objective of anti-money laundering procedures that Inteli Express System implements is to ensure that customers engaging in certain activities are identified to a reasonable standard, while minimizing the compliance burden and impact on legitimate customers.

Other guiding principles of the system created for the purposes of anti-money laundering and financing of terrorism are:

•  Mitigation of risks of the System being used as an intermediary in Money laundering and financing of terrorism operations;
•  Protection of the System from goodwill and financial losses arising in connection with attempts to use the System for the purposes of operations connected with Money laundering and financing of terrorism;
•  Detection of operations subject to obligatory control and detection of suspicious operations, registration of such operations and maintain detailed records of all transactions, and report such activities providing timely and comprehensive advice to law enforcement;
•  Ensuring of continuous compliance with set anti-money laundering and financing of terrorism requirements monitoring;
•  Inteli Express staff participation in the realization of internal control programs for the purposes of anti-money laundering and financing of terrorism;
•  Observance of confidentiality status of the information obtained in the process of activities.

Inteli Express System is committed to assisting governments combat the threat from money laundering and terrorist financing activities around the world. For that purpose Inteli Express System has setup a highly sophisticated electronic system.

OUR COMPLIANCE REGIME
Inteli Express System implemented a compliance regime, as laws require from financial institutions, including appointment of a compliance officer, preparation of policies and procedures, periodic review of their effectiveness, and ongoing compliance training of our staff.

The System is connected to the network of the Office of Foreign Assets Control ("OFAC") of the US Department of the Treasury, uses its database and software “OFAC Data Download“. The database contains a Permanently Updated List of terrorists, drug traffickers and other Specially Designated physical persons and legal entities.     

Software of Inteli Express identifies data of all persons involved in money transfer (both of the receiver and the sender) as well as in other financial transactions are verified online with data of the Permanently Updated List of terrorists, drug traffickers and other Specially Designated physical persons and legal entities published by the Office of Foreign Assets Control. Partial as well as full verification of identification data is carried out.

The DOW JONES RISK AND COMPLIANCE Feed service is available to be collected by the Company via secure HTTP. The secure HTTP account was authorized and administered by Dow Jones. The Service was hosted on the Company management system and was created Company’s own searching tools. The full database is available on a monthly basis, while the incremental updates are provided on both a daily and weekly basis.

Service means the global database of PEPs, their relatives and close associates, wrong persons with details of high profile people, not on an official list, but reported in publicly available sources as being accused or convicted of serious crimes including corruption, financial crime, organized crime, terror, trafficking and war crimes. The unrivalled Dow Jones Watch list Compliance Solution includes: Maximize compliance efforts by screening against sanctions, law enforcement and other official lists including those issued by OFAC, European Union, UN and HM Treasury, Know your customer by accessing over 500,000 detailed profiles of PEPs, their associates, relatives, friends and colleagues from every country worldwide.

Software of Inteli Express identifies data of all persons involved in money transfer (both of the receiver and the sender) as well as in other financial transactions is verified online with data of Dow Jones Watch list. While partial or full verification of identification of data, if the person is verified as PEPs, a message “Monitoring alert” will appear on the program; the transaction will not be blocked but a message will be immediately sent to the responsible person of the Company Monitoring Service.The System suggests setting contractual relationships only with credit and finance organizations that comply with AML and financing of terrorism actions themselves.