AML and CTF Policy

Verizun Investments is firmly committed to adhering to all applicable laws and regulations concerning anti-money laundering (AML) and counter-terrorist financing (CTF). We implement comprehensive policies and procedures to ensure compliance with relevant legislation, regulations, and best practices.

Definition of Money Laundering and Terrorist Financing

Money laundering refers to:

• Concealment and Transfer: Converting or transferring property derived from criminal activity to conceal its illicit origin or to assist others in evading legal consequences.
• Acquisition and Use: Possessing or using property obtained through criminal activities with the knowledge of its unlawful origin. I agree to promptly notify Verizun of any material changes to my details, including my residential address and identity.
• Disguise: Concealing the true nature, source, ownership, or movement of property derived from criminal activity.

Terrorist financing involves providing financial support to individuals, groups, or organizations involved in terrorism, as outlined in applicable legal frameworks.

Objectives of the Policy

• To prevent Verizun Investments from being exploited for illegal activities such as money laundering or terrorist financing.
• To comply with all applicable laws and regulations while mitigating risks associated with financial crimes.

Customer Warranties

By engaging with Verizun as a client or supplier ("Customer"), you agree to the following:

• Compliance: You comply with all applicable AML/CTF laws and regulations.
• Legitimate Funds: The funds you deposit or use are not derived from illegal activities.
• Prohibited Activities: You will not use Verizun’s services to finance illegal activities.
• Notification: You agree to promptly notify Verizun of any suspicion of money laundering, terrorist financing, or other illegal activities.
• Information Disclosure: You will provide requested documents and information to comply with legal and regulatory requirements.
• Due Diligence: You acknowledge that Verizun may perform due diligence, including verifying your identity and conducting enhanced checks where necessary.

Reporting Obligations

Verizun Investments is obligated to report any suspicion of money laundering or terrorist financing to the appropriate Financial Intelligence Unit (FIU).

Risk Assessment

Verizun identifies and assesses potential risks of money laundering or terrorist financing and implements measures to mitigate them to acceptable levels. Customer transactions and activities are continuously monitored to ensure compliance.

Customer Due Diligence (CDD)

Information required:

For individuals:

• Full name
• Personal identification number
• Date and place of birth
• Residential address
• Relationship to the customer (if applicable)

For Legal Entities:

• Name or business name
• Registration number and date
• Directors, management board members, and authorized representatives
• Contact details

Verification Documents:

For Individuals (one of the following):

• Identity card, passport, or driving license
• Temporary travel document
• Refugee travel document
• Other valid identification issued under applicable laws

For Legal Entities:

• Registry card or certificate of incorporation
• Equivalent official documentation

Enhanced Due Diligence (EDD)

EDD is applied in high-risk scenarios, such as:

• Doubts about the accuracy of submitted documents.
• Politically exposed persons (PEPs) or customers from high-risk jurisdictions.
• Transactions involving high-risk third countries.
• Unusual activity flagged during monitoring.

EDD measures include:

• Collecting additional information on customers and beneficial owners.
• Verifying the source of funds and wealth.
• Obtaining senior management approval for business relationships.
• Enhanced monitoring of transactions and customer activities.

Monitoring Customer Activity

Verizun conducts ongoing monitoring of customer activity through:

• Real-Time Monitoring: Tracking transactions as they occur.
• Post-Event Monitoring: completed transactions to identify risks.

Monitoring ensures that transactions align with the customer's risk profile, activities, and declared information.

AML Principles

Verizun maintains the following minimum standards:

• Risk-based approaches to identify and manage risks.
• Comprehensive customer identification and verification procedures.
• Monitoring customer activities to identify suspicious transactions.
• Reporting suspicious activities to relevant authorities.
• Maintaining appropriate records for at least five years.
• Training employees to understand and comply with AML/CTF policies.

Sanctions Policy

Verizun strictly complies with global sanctions lists, including those from:

• United Nations
• European Union
• UK Treasury
• US Office of Foreign Assets Control (OFAC)

Transactions involving sanctioned individuals, entities, or countries are prohibited.

Data Retention

Verizun retains identification and verification documents, as well as records of transactions, for a minimum of five years after the termination of a business relationship, in compliance with AML laws.

This AML and CTF Policy ensures that Verizun Investments remains a safe and compliant platform, protecting against financial crimes while adhering to the highest standards of regulatory compliance.