Meaning of the document
AML Act
(1) For the purposes of this document, the AML act means Act No. 253/2008 Coll. on some measures against legalization of revenues from criminal activities and terrorism financing, as amended.
Legalization of revenues from criminal activities
(1) According to the AML act, legalization of revenues from criminal activities means activities that are to cover illegal origin of any economic benefit emerging from criminal activities with the aim of establishing an appearance that the property benefits were obtained in compliance with law; the above stated activities include for example:
(1) According to the AML act, terrorism financing includes:
(2) Terrorism financing also means financing of mass destruction weapons distribution, i.e., collection or provision of financial means or any other property while knowing that it will be used – even partially – by the distributor of mass destruction weapons or for such weapons distribution in contradiction with international law requirements.
(1) According to the AML Act, an obliged person means the company CRP Unio Limited s.r.o., with its registered seat in Říční 456/10, Malá Strana, 118 00 Praha 1, company ID: 216 05 688 (the “Company”) for activities of providing of services related to a Virtual assets.
(1) For the purposes of this document, a customer means any natural person or legal entity:
(2) It is not decisive whether it is a natural person or a legal entity carrying business or not. In case of a legal entity, it is supposed that one concrete natural person always acts on behalf of it (e.g., a member of the statutory authority, an employee, etc.).
(1) For the purpose of this document, the virtual assets service means any handling of customer’s property or provision of a service to a customer as mentioned in §4(8) of AML Act, and contain next services:
According to §4(9) of AML Act, virtual asset means an electronically storable or transferable unit that is capable of performing a payment, exchange or investment function, unless it is excluded by specific criteria under the Act on Payments.
(2) A virtual assets service also means any service provided without appropriate authorization, registration or license, even though it would be in contradiction with law.
(1) A business relation means a contractual relation by and between the customer and the company CRP Unio Limited s.r.o., based on which the customer is provided with virtual assets service. A business relation is usually established on the basis of a frame contract on provision of virtual assets service. The Company provides virtual assets service on the basis of business relations only, not on the basis of an agreement on a lump-sum payment transaction.
(1) Customer’s instruction means any instruction issued by the customer or by a person authorized to act in this matter on customer’s account, requiring for the Company to provide a virtual assets service or to make another act within the scope of the virtual assets service provided, e.g., a Virtual asset order.
(2) It is not important in which way was the customer’s instruction handed over to CRP Unio Limited s.r.o. (electronically, by phone, personally or in any other way). It is also not important whether the customer’s instruction was accepted or not.
(1) The obligations set out in this document apply to certain groups of employees - in particular the employees, the AML officer and the responsible person. They also apply to any person who may encounter a suspicious transaction (Chapters IV1. – IV.3) or perform any of the activities described in this document, as well as other persons. All of these people may potentially encounter trade suspected of attempting ML-FT.
(2) It is irrelevant whether it is a direct employee or a work performed on the basis of another relationship or without any relationship (even as a free aid).
(3) Unless the Company is capable of ensuring the full and error-free performance of its obligations under this document and the Risk Assessment, it must reduce or even suspend virtual assets service activity until such a defect ceases, unless this is in conflict with the obligations under the legal regulations. This is the case, for example, in the event of a sudden failure of employees and replacement by temporary underexperienced assistance. Thus, ML-FT prevention activities must at all times be adequately staffed (both qualitatively and quantitatively). Responsibility for meeting this obligation lies with the responsible person.
(4) Furthermore, the responsible person is responsible for selecting the persons who are bound by this document. The responsible person shall always verify that the employee is able to fulfil the obligations laid down in this document before recruiting a new employee for the position concerned by this document or before transferring an existing employee to that position. These abilities / skills include:
(1) For the purposes of this document, an employee means any person who is – in the course of fulfilment of its work tasks – in the name of the company CRP Unio Limited s.r.o.:
(2) An employee is a direct employee as well as a person performing such activities on the basis of another relation than the employment contract, including a negotiator.
(3) An employee is also a person who is not an employee at the present moment, but he/she was authorised (even though just temporarily) to perform an activity, the realisation of which is set to an employee by this document.
(1) For the purposes of this document, persons related to customers mean all and any of the following persons (natural persons or legal entities):
(1) A person identified in this document as an AML officer means a person authorised to arrange compliance of business activities of the Company with legal regulations in the field of avoidance of proceeds from criminal activities, terrorism financing and application of international sanctions. It concerns mainly arrangement of compliance with the following regulations:
(2) Generally, it is supposed that the AML officer is a person directly governing.
(3) The person appointed in the Company and authorised to execute the position of an AML officer is specified in Annex No. 2.
(1) The responsible person of the obliged person means – for the purposes of this document – any member of the statutory authority of the obliged person.
(1) For the purposes of this document the virtual assets service value means the general value of property being a subject of the virtual assets service. It is the value of the property as made available by the customer to the Company for the purpose of the virtual assets service provision respectively the value that is to be transferred, exchanged or otherwise used. In case of mutually related virtual assets service, the virtual assets service value is the sum of the services.
(1) For the purposes of this document, the sum which is set in Euro (EUR) means an equal value in any currency converted based on the exchange rate announced by the Czech National Bank and valid for the day. If the exchange rate is not available that day yet, the exchange rate for the previous day applies. For current Exchange rates list of the Czech National Bank see https://www.cnb.cz/cs/financni-trhy/devizovy-trh/kurzy-devizoveho-trhu/kurzy-devizoveho-trhu/.
(1) The procedures set forth in this document are also binding on persons acting in the performance of virtual assets service or in establishing business relationships on behalf of or for the account of the Company mainly for authorized representatives (hereinafter referred to as “representative”). The responsible person shall ensure that the representative accepts and / or fully integrates these procedures into his / her own internal procedures. The responsible person shall also ensure compliance with the obligations set out in this document in the representative's environment.
(1) According to the AML Act, a Politically Exposed Person („PEP“) means a natural person who is or was in an important public function with regional, national or even higher importance, for example:
(2) A PEP is also considered to be a person close to the above stated person, mainly:
(3) A PEP is also considered to be a person from the "business surroundings", being:
(1) A beneficial owner is always related to a legal entity only. According to the AML Act, a beneficial owner means a natural person with factual or legal possibility of direct or indirect application of decisive influence in a legal entity, in a fiduciary fund or in any other legal organisation without legal personality. It is supposed that in case of fulfilment of conditions contained in previous sentence, the following person is a beneficial owner:
(1) According to Section 74 et conseq. Act No. 90/2012 Coll., on Commercial Companies and Cooperatives (Business Corporations Act), a controlling person means a natural person or legal entity who may directly or indirectly apply decisive influence in a business corporation. The indirect corporation means the influence executed through another person or other persons.
(2) The controlling person(s) is/are:
(3) For better understanding of conditions under which a natural person or a legal entity may be considered a controlling person, we recommend studying relevant stipulations of the Act on business companies and co-operatives (Business Corporations Act).
Procedure before business relation establishment
(1) Prior to establishing the business relationship, the employee will create a risk profile of the customer. This is a characteristic of the particular customer.
(2) If a business relationship has been established in the past and it lasts (the customer uses other company services), the risk profile will be updated when establishing any further business relationship.
(3) The risk profile is compiled with respect to all the information that CRP Unio Limited s.r.o. has about the customer, i.e., not only the information obtained during the initial identification and check but also other information that the employee acquires and also with regard to the information that the company possibly has from previous business relationships that have been terminated.
(1) The customer's risk profile means the assessment of the customer that represents a potential risk that the services of CRP Unio Limited s.r.o. may be misused by the customer for the purpose of legalizing proceeds of crime or for financing of terrorism. As part of the risk profile, the customers are classified into the following groups according to the risk factor that has occurred in their case:
(2) The risk profile is crucial in two respects:
(1) The risk factor means the characteristic of the customer, the product provided to the customer, or the way it is provided to the customer, which increases the risk that the services of CRP Unio Limited s.r.o. may be misused by the customer for the purpose of legalizing proceeds of crime or for financing of terrorism.
(2) Due to the presence or absence of the risk factors, the customer is assigned the type A, B, C, D or E risk profile.
(1) The customer is assigned the risk profile of the type A if there are no known risk factors which would assign the customer the risk profile of type B, C, D or E.
(2) A customer with a risk profile of type A does not represent for the Company no, or only very small (negligible) risk in terms of money laundering and terrorism financing, in case of:
(1) The customer is assigned the risk profile of the type B, C or D if there are no known risk factors which would assign the customer the risk profile of type E and at the same time, any of the risk factors listed in the Risk Assessment document as risk factors of the type B, C or D are found.
(2) A client with a Type B risk profile poses a low risk to the CRP Unio Limited s.r.o. in terms of money laundering and terrorist financing. To obtain this risk profile, the client must meet the following conditions:
(3) A client with a Type C risk profile poses a money laundering and terrorist financing risk to the Company. To obtain this risk profile, the client must meet the following conditions:
(4) A customer with a Type D risk profile poses a high risk to the Company in terms of money laundering and terrorist financing. He is always an EDD subject.
(5) A customer with the risk profile of the type B, C or D represents for CRP Unio Limited s.r.o. the potential risk from the point of view of legalization of proceeds from crime and financing of terrorism and therefore all employees, including the AML officer, must:
(1) The customer is assigned the risk profile of the E type in the event that any of the risk factors listed in the Risk Assessment document is found with the customer, making the customer unacceptable.
(2) A customer with the risk profile of the type E represents for CRP Unio Limited s.r.o. extremely high risk from the point of view of the legalization of proceeds from crime and the financing of terrorism. In the event that the customer is assigned the type E risk profile, the business relationship will not be established with the customer, or the business relationship with the customer will be terminated and no other service will be provided for the customer. It is assumed that the customer in this situation no longer meets the customer's eligibility conditions.
(3) In this case, the termination of the business relationship or refusal to provide any service will be ensured by the AML officer. Without unnecessary delays, the AML officer will take all necessary steps to ensure that the business relationship is effectively and legally discontinued. The AML officer will also prevent any new services from being provided to the customer until the business relationship is terminated.
(4) In addition, it is necessary to pay close attention when assessing whether the customer's behaviour does not show signs of suspicious trade under the Chapter IV.1
(1) A business relationship can only be established with the customer if all three of the following conditions are met:
(2) The business relationship is established by signing the documents on the basis of which the business relationship is established, or when the services are made available for the customer, whichever comes first.
(1) In addition, when establishing the business relationship, the customer will be obliged to notify all changes to the data the customer has provided during the establishment of the business relationship. These include in particular:
(2) The Customer must make the notification of the change of the data or of its completion without any delay, but not later than prior to being provided with the next virtual assets service. The customer will also be informed that failure to notify a change may be a reason for termination of the business relationship.
(1) The Company rejects to enter into a business relationship with a customer if:
(2) In the event when the establishment of business relationship is refused, a closer attention of employees shall be focused on the facts, whether the behaviour of a customer, due to which such a situation emerged, is typical of suspicious business characteristics, pursuant to the Chapter IV.1.
(3) The document titled Risk Assessment may determine for individual types of the customers, services or services provision methods even other circumstances, under which the business shall not be performed. Next, it can determine the rules of customer acceptance – i.e., features of a customer who is not allowed to be provided with the services (or certain type of service). Our employee is obliged to respect the extended list.
List of obligations
(1) Within the duration of the business relationship entered into with a customer, the Company is obliged to perform, in particular, the following:
(2) The Risk Assessment document may determine, for each customer risk group, the frequency or circumstances that trigger the need to meet individual obligations during the business relationship, as well as the intensity with which those ongoing obligations need to be met. It is the fulfilment of a risk-oriented approach to monitoring and managing the business relationship.
(1) Whenever doubts arise as to the information or data (obtained as part of customer identification or control), the employee shall verify this information without undue delay. This is done by verifying the information either from publicly available sources or by contacting the customer to provide appropriate explanations and possibly documents.
(1) Within the duration of the business relationship, all the employees shall assess whether the behaviour of a customer or the persons acting on behalf of a customer is not typical of suspicious business. This kind of behaviour is understood as the behaviour related to the services, as well as the behaviour of a customer towards the company CRP Unio Limited s.r.o., which is not directly related to the provision of services.
(2) This assessment shall be performed by the employee, according to Chapter IV.1.
(1) Throughout the business relationship, all employees continually update the customer's risk profile. This means that if there is a circumstance that causes a worsening of the customer's risk profile, there will be a change, or vice versa - if circumstances worsening the customer's risk profile disappear, it will change in the opposite direction, if permissible. The rules and factors set out in Chapter II.6 and in the Risk Assessment will be used to update the risk profile.
(2) The frequency of updating the customer's risk profile is determined by the Risk Assessment.
(3) The employee always keeps a record of changes in the customer's risk profile, which enables the situation to be reconstructed - i.e., it includes information on the reason for the change, the method of finding, source and eventual verification of the circumstances, date and information on the currently valid risk profile data. The history of changes in the risk profile must show all its changes, i.e., previous information is not deleted, only new one is added.
Customer's data changes and information added
(1) In the course of the business relation duration, the employee must check the validity and completeness of the customer's data, which is stored in the customer's file. In particular the following ones:
(2) In the event, when customer's identity card validity has expired, i.e., the identity card, on the basis of which a customer, a natural person, was verified, there is no need to have the data on new identity card. However, if customer's identification data has been changed, there is necessary to verify the new data from his/her identity card and record even the information on his/her identity card in which the new data is stated. The data on original identity card shall not be deleted.
(3) Every change or data added shall be recorded by the employee. The record shall be entered by the employee who found out such a data change or who found out the information which shall be necessarily added, or who was given such information on change from a customer.
(4) A change or completion shall be performed as follows: the originally recorded information shall be supplemented with the new one. It is necessary to proceed in such a way which allows us to distinguish whether this is the case of a data change or just a data completion (i.e., whether the originally recorded data stays valid or not). Moreover, it shall be apparent who from our employees and when (date) has entered the data change or data completion, or the source of data verification shall be identified.
(5) If this is the case of data change, the originally recorded data cannot be deleted, in spite of the fact such data is not valid anymore; it is necessary to keep it stored as the data which was valid in the past (including the documents which supported the data – if required).
(6) Furthermore, if it is required during the procedure of changed or supplemented data sourcing to support such a new information with any document or verification upon any kind of declaration, power of attorney or other document, then it is necessary to submit such a document or perform its verification within its full scope.
Continuous verification of a customer
(1) The continuous verification of a customer is aimed to trace the services provided to a customer during the business relationship in order to be able to verify whether the transactions and acts were in compliance with the facts known to the Company about the customer.
(2) This monitoring is essential to assess whether the services provided to the client do not exhibit the characteristics of suspicious business under Chapter IV.1. In particular, the automated system assesses the following information:
(3) Continuous verification shall be understood as an assessment procedure focused on whether a customer was provided with services that correspond with his/her property relations and with the intended purpose of a service (related to a product provided to a customer). If a customer uses the services from company CRP Unio Limited s.r.o. beyond the declared property relations or contrary to the intended purpose of the business relationship (i.e. the product), it warrants further investigation to determine if it constitutes suspicious business.
(4) Customer's risk profile is also a key factor in continuous verification. If a customer has a Type B, C, D risk profile, the assessment increases:
(5) Special attention is focused on PEPs active outside the EU or within the EU, where risk factors are identified. Such persons are considered risky due to potential property of corruption origins or other suspicious behaviors. Alerts are preset in the system based on regularly received income for PEPs, including reserves from savings. If such a customer uses services beyond known financial means, documentation of fund sources is required.
(6) If an employee suspects a customer has provided false, distorted, or incomplete information, relevant documents must be requested from the customer for verification (e.g., account statements, accounting records, declarations from responsible accounting personnel, etc.). Only original documents or certified copies are accepted. Once submitted, continuous verification may be considered passed.
Customer’s Business Control
(1) Customer’s business control involves additional monitoring during the business relationship.
(2) In particular, this procedure monitors:
(3) This monitoring is essential to assess whether the services provided to a customer do not exhibit characteristics of suspicious business under Chapter IV.1.
(4) Customer’s Business Control is triggered when a customer exceeds the initially set limit during the initial control. This procedure is performed by the employee monitoring services provided to the customer. The automated system assesses:
(5) If a customer is assigned a new risk profile during business control, the employee relies on the Risk Assessment document, which outlines processes and intensity of obligations for each customer risk group. In this case, the employee requests:
How to proceed in case of suspicion
(1) If suspicion arises, particular attention is given to assessing whether customer behavior exhibits suspicious features, in accordance with Chapter IV.1.
Records of continuous and business control
(1) A record must be made and kept of each continuous check, ensuring all events can be reconstructed (including periodic scans, issued alerts, handling personnel, data obtained, and any other relevant documents).
Customer's obligation to provide us with cooperation
(1) Customers are obligated to undergo continuous verification, providing all required information and supporting declared facts with documents (if required by the employee). Failure to provide sufficient cooperation results in denial of service (i.e., no transfer of financial funds with the Company), termination of the business relationship (per Chapter III.2), and is considered suspicious business per Chapter IV.1, requiring adherence to the procedure outlined in Chapter IV.2, with mandatory reporting of suspicious business.
Applying the risk-oriented approach
(1) The Risk Assessment document determines information details and document reliability levels required for each customer type, service, or method of service provision. These requirements are enforced at the cash counter. The document also specifies the level of document reliability accepted during verification procedures (e.g., excluding simple customer declarations).
Ban to provide service
(1) A customer will not be provided with the service and the business relationship with a customer will be terminated if any of the following facts emerge:
(2) When any of these situations arise, the employee must promptly report it to an AML officer and ensure that the customer is denied services by the Company. The AML officer will oversee the termination of the business relationship both de facto and de jure. Additionally, the employee must exercise heightened attention to assess whether the customer's behavior exhibits suspicious business characteristics as per Chapter IV.1.
Suspicious business in general
(1) Suspicious business shall be understood as a service provided under circumstances suggesting money laundering or terrorism financing.
(2) It can also refer to customer behavior not directly aimed at receiving a service, but raising suspicion of illegal activity or an attempt to establish a business relationship.
(3) Features and circumstances indicating suspicious business:
(2) This list is non-exhaustive; practical experience may include other circumstances suggesting money laundering or terrorism financing.
(3) Presence of these features does not definitively indicate suspicious business.
(1) Assessment is conducted by employees:
(2) Factors include information provided during initial or continuous verification; AML officers may consider additional relevant circumstances not directly listed here.
(3) Employees cannot state to customers whether their assessment concludes suspicious business.
(1) When identifying and evaluating a suspicious transaction, the employee also takes into account the customer's risk profile, which has been assigned or updated according to Chapter II.6.
(2) Customers with a risk profile of type B require careful assessment when evaluating potential suspicious transactions. Customers with a risk profile of type E will not receive services, and their business relationship will be terminated.
(3) Customers with a risk profile of type B must provide credible documents to substantiate claimed facts.
(1) Always suspicious business includes:
(1) Steps in case of suspicious business:
(2) If customer identification or verification cannot be completed due to non-cooperation, report suspicious business per Chapter IV.2, if some customer information is available.
(1) Ensure employees have unlimited access to customer information, business relationships, services provided, and related documents and internet sources for assessing suspicious business. Information retrieval must be automated.
(1) The Company shall communicate, at the FAU's request, information on the services or trade relations for which the FAU is investigating within a specified period. The responsible person shall ensure the submission of documents on these transactions or give them access to authorized employees of the FAU.
(2) In case of personal contact, the authorized employees of the FAU shall produce a service card issued pursuant to the Act on Implementation of International Sanctions. The model of this card is a part of Decree No. 53/2017 Coll. FAU employees are not obliged to give their name.
(3) If requested by the AML officer or responsible person, each employee is obliged to provide assistance to him in the performance of this duty.
(1) The employees, a person responsible, and an AML officer are obliged to follow the confidentiality obligation on the facts related to:
(2) Everyone who becomes aware of these facts is obliged to keep them confidential.
(3) The confidentiality obligation shall not be extinguished upon termination of employment or contractual relationship.
(1) The responsible person is obliged to ensure all employees undergo training, including those who may encounter suspicious business. The training shall cover rules, procedures, risk assessment, the AML Act, and other relevant regulations.
(2) Training must occur at least once every 12 months and before new or transferred employees start their positions.
(3) The responsible person maintains and archives attendance and training content records.
(1) The responsible person shall prepare a report evaluating CRP Unio Limited s.r.o.'s activity in preventing money laundering and terrorism financing at least once every 12 months.
(2) The report includes:
(3) Conclusions and assessments must be justified.
(4) If prepared by someone other than the AML officer, the report must include the officer's view on completeness and correctness.
(5) The report is reviewed by the company statutory body within 4 months after the assessed period.
(6) Evaluation details must be traceable.
(7) The assessment report is archived for 5 years.
(1) All the data and documents related to the business relationship shall be archived. In particular, this is the case of filled in forms, original documents or copies of documents submitted by a customer, and other company internal records. All the data and documents related to a specific service shall be archived analogically.
(2) A part of these documents may be also in a digital form. Any other way of data and documents archiving may be decided by a person responsible.
(1) The employee shall, pursuant to the AML Act, be authorised to make and keep the copies of identity cards or other documents records, upon which the identification is performed.
(2) In the event when from a copy made and archive is apparent the data which shall be otherwise obligatory recorded applying the way described herein, then it is not necessary to enter the data into the form. It is sufficient when the data is clear from the copy which was made.
(1) From each recorded information and archived documents shall be apparent:
(2) Next, an AML office shall ensure safe archiving of the copies of filed notifications on a suspicious business, a document on their lodging, eventually an advice on their delivery.
(1) If the data or documents are recorded in a digital form, then the back-up shall be performed by a person responsible or by a person authorised to do so.
(2) Archiving some documents in a digital form is not allowed, which results from the provisions of the AML Act that prescribes some documents to be archived only as the original documents or certified copy – this is, in particular, the case of the powers of attorney and identification documents.
(1) Pursuant to the AML Act the Company is obliged to archive the data and documents for the following period:
(1) The term of traceability stated herein shall be understood as the state when it is possible, in case of certain procedure, determine retrospectively, why a specific action was performed (what was the reason), in what circumstances, what preceded that action, and eventually what followed that action, what exactly was done, and who and when performed the steps.
(2) What shall be also traceable retrospectively:
(3) Due to this reason is necessary that all the records (digital or documentary), which are made in accordance with the present document and archived, contain at least the following information (if this kind of information is not apparent or cannot be deduced from other documents):
(1) If any of the procedures stated herein or procedures related to the establishment and administration of business relationships are performed in an automated way, especially using computers, then it is necessary to ensure that all the obligations, procedures and measures resulting from the present document and other legal regulations are being adhered to within their full scope. This is the responsibility of a person responsible, an AML office, and the employee who controls, checks, sets and tests the automated system.
(2) Information or other systems that perform the automatic data-processing shall be developed, calibrated and shall have sufficient capacity to be able to react correctly in each situation which may be assumed, however, only with a low probability. This includes, in particular, immediate alerts and reporting, correct hardware setting, regular backups, testing and system maintenance.
(1) The responsible person shall assess, at least every 12 calendar months, whether the provisions set out in this document and in the Risk Assessment document are current, proportionate to the nature, scale and complexity of currency exchange services and related activities. If necessary, it performs or arranges for updates to keep the regulations current and in line with the actual situation.
(2) In addition to this regular 12-month interval, the responsible person shall, without undue delay (ideally in advance), review and update this document and the Risk Assessment if any such need arises:
(3) The responsible person will always create a written record of the assessment result and any further steps (whether the update and other details have been made).
(4) If there is a change in the Risk Assessment, the responsible person shall record the procedures used to draw up or update the Risk Assessment and shall also record the reasons on which it has drawn the conclusions contained therein.
(5) Furthermore, if the procedures set out in this document or in the Risk Assessment are substantially changed, the responsible person will organize training for the staff affected. It will record the content and attendance of the training according to the Chapter V.4.
(6) Changes in this document and in the Risk Assessment are approved by the Company's statutory body.
(1) If the procedures set out in this document or in the Risk Assessment are changed, the responsible person shall verify that the information provided by CRP Unio Limited s.r.o. about customers (information obtained during the identification and control of the customer and any other information used to prevent ML-FT), its content and scope correspond to new obligations. If not, the responsible person will oblige the employees to supplement or update this information. The employee shall always do so at the latest before making another trade with the customer.
(1) Monitoring of the compliance with rules and procedures stated herein shall be performed by a person responsible. A person responsible may forward a partial monitoring towards an AML officer or other person. All the employees and an AML officer are obliged to undergo such a monitoring. The monitoring is to be performed in place, analysing the data and documents, or applying other ways of monitoring.
(2) The monitoring shall be performed regularly, ideally once a month. A person performing the monitoring selects a control sample, on which he/she checks whether the procedures stated herein and prescribed by legal regulations were adhered to. The ideal situation is when a control sample is in compliance with all the business relationships or services provided within the monitored period, however, this is not possible due to capacity reasons, thus a random selection is sufficient.
(1) A person that performs the internal monitoring shall, when the monitoring is finished, draw up a report. This report sample is shown in the Annex No. 1.
(1) Each person that has found out any infringement shall report this state immediately to a person responsible, also in the case when the infringement was caused by this person.
(1) In the event when a breach of rules and procedures prescribed herein are found out from the monitoring or notification, such a breach shall be assessed individually, in particular upon the level of seriousness and the extent, up to which these could jeopardize the effectiveness of measures applied against the legalization of the proceeds of crime and terrorism financing. A personal responsibility shall be then inferred on employees within the scope of applicable labour legal regulations. A person responsible shall, within the scope of his/her possibilities, simultaneously adopt the measures to prevent a repeated breach (repeated training of the employees, approval of additional measures, etc.).
(1) All the persons to which is the present document shall be aware of the fact that any breach (infringement) of the rules and procedures stated herein would most probably result also in a breach of the provisions stated within the AML Act, and therefore the Company may be subject to a sanction or even the withdrawal of business license may be applied.
(1) Persons responsible, i.e., an AML officers, are obliged to perform permanent monitoring of the development in the field of measures against legalization of proceeds of crime and financing of terrorism (i.e., the Acts, Decrees, Notices, etc.). Relevant regulations are published by the FAU (Financial Analytical Office) on its websites www.financnianalytickyurad.cz, and also on the websites of the Czech National Bank at: CNB Legalization of Proceeds of Crime. The websites shall be understood as information source only, and a person responsible shall be actively involved in this kind of activity.
(1) In the event when the mentioned regulations are amended, or the new regulations come into force, the person responsible, i.e., an AML officer, shall implement such amendments to the present document to ensure the compliance of the present document with these regulations, a AML officer is also obliged to ensure the training of all the persons who shall be familiarized with such amendments.
This Policy is approved by Senior Management of the company.
Effective from May 2024