AML POLICY

1. The conversion or transfer of property derived from criminal activity or property obtained instead of such property, knowing that such property is derived from criminal activity or from an act of participation in such activity, 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 such an activity to evade the legal consequences of that person’s actions;

2. The acquisition, possession or use of property derived from criminal activity or property obtained instead of such property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation therein;

3. The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property derived from criminal activity or property obtained instead of such property, knowing that such property is derived from criminal activity or from an act of participation in such an activity. ‘Terrorist financing’ means the financing and supporting of an act of terrorism and commissioning thereof within the meaning of Cap. 615 of the Penal Code of Cyprus.

1. To prevent Theny Alliance Global from being used for a financial crime so as to comply with all applicable legal requirements; and,
2. To ensure that the most appropriate action is taken by Theny Alliance Global to mitigate the risks associated with financial crime.

1. You warrant that you comply with all applicable anti-money laundering laws and regulations, including but not limited to the AML/CTF laws and associated rules and regulations as amended from time to time;
2. You warrant that the money you use to deposit your account has not been or will not be related to any money laundering or other illegal activities under applicable laws and regulations;
3. You will not use your investment in Theny Alliance Global for the purpose of financing illegal activities;
4. You agree to promptly notify us of any event that is related or you suspect to be related to money laundering, terrorist financing or other illegal activities;
5. You agree to promptly provide us with all information and documents that we reasonably request in order to comply with all applicable laws and regulations relating to anti-money laundering;
6. You acknowledge and agree that Theny Alliance Global will conduct initial simplified due diligence and verify your identity and may conduct enhanced due diligence if required by applicable laws and regulations.

Theny Alliance Global is obliged to report to the Financial Intelligence Unit in the event of suspicion of money laundering or terrorist financing.

Theny Alliance Global is committed to identify and assess any money laundering or terrorist financing risks as well as to mitigate these risks to an acceptable level. As part of the risk assessment, we monitor and review the operations of customers.

Theny Alliance Global takes steps to identify our customers and check whether they are who they say they are.

1. Full name; and
2. Personal identification code; and
3. Date and place of birth; and
4. Place of residence or seat; and
5. If the person is not the customer, the person's relationship to the customer. For a legal person:
6. Name or business name of the legal person; and
7. registry code or registration number and the date of registration; and
8. names of the director, members of the management board or other body replacing the management board, and their authorization in representing the legal person; and
9. details of the telecommunications of the legal person.

1. identity card;
2. passport;
3. diplomatic passport;
4. seafarer’s discharge book;
5. alien’s passport;
6. temporary travel document;
7. travel documents for refugee;
8. certificate of record of service;
9. certificate of return;
10. permit of return; valid travel document issued in a foreign country; or
11. the driving license that meets the requirements provided for in subsection Cap. 374B of the Identity Documents Act of Cyprus.

1. registry card of the relevant register;
2. registration certificate of the relevant register, or
3. document equal to the document specified in clause 1 or 3 above.

1. upon identification of a person or verification of submitted information, there are doubts as to the truthfulness of the submitted data, the authenticity of the documents or identification of the beneficial owner;
2. the customer is a politically exposed person, except for a local politically exposed person, their family member or a close associate;
3. the customer is from a high-risk third country or its place of residence or seat or the seat of the payment service provider of the payee is in a high-risk third country;
4. the customer is from such country or territory or its place of residence or seat or the seat of the payment service provider of the payee is in a country or territory that, according to credible sources such as mutual evaluations, reports or published follow-up reports, has not established effective AML/CFT systems that are in accordance with the recommendations of the Financial Action Task Force, or that is considered a low tax rate territory;

1. gathering additional information about the customer and its beneficial owner;
2. gathering additional information on the planned substance of the business relationship;
3. gathering information on the origin of the funds and wealth of the customer and its beneficial owner;
4. gathering information on the underlying reasons for planned or executed transactions
5. receiving permission from the senior management of Theny Alliance Global to establish or continue a business relationship;
6. improving the monitoring of a business relationship by increasing the number and frequency of the applied control measures and by choosing transaction indicators that are additionally verified;

1. a) obtaining approval from the senior management of Zantepay to establish or continue a business relationship with the person and making sure that only senior management of Theny Alliance Global gives approval for a new business relationship;
2. applying measures to establish the origin of the wealth of the person and the sources of the funds that are used in the business relationship or upon making occasional transactions;

1. identify any unusual activity, flagging up transactions/activities for further examination;
2. check transactions made in a business relationship in order to ensure that the transactions are in concert with the obliged entity’s knowledge of the customer, its activities and risk profile;
3. regularly update relevant documents, data or information gathered in the course of application of due diligence measures;
4. identify the source and origin of the funds used in a transaction;
5. pay more attention to high-risk transactions.

1. “Real-time” monitoring of activities/transactions as they arise or are about to take place;
2. “Post-event” monitoring within defined parameters.

1. Establishing and maintaining a Risk-Based Approach towards assessing and managing the money laundering and terrorist financing risks to the company;
2. Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer procedures, including enhanced due diligence;
3. Establishing and maintaining risk-based systems and procedures to monitor on-going customer activity;
4. Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
5. Maintenance of appropriate records for the minimum prescribed periods;
6. Training and awareness for all relevant employees.

Theny Alliance Global is prohibited from transacting with individuals, companies, and countries that are on prescribed Sanctions lists. Theny Alliance Global will, therefore, screen against the United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.

Theny Alliance Global will retain documents related to the identification information which serve the basis for identification and verifications of persons, and the documents serving as the basis for the establishment of a business relationship as well as certain other documents and information as per AML laws and regulations no less than five years after termination of the business relationship.