ANTI-MONEY LAUNDERING POLICY
This AML Policy was published on February 2023.
Platos LTD (or “the Company”) Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designed to prevent and mitigate possible risks of the Company being involved in any kind of illegal activity. This document is a short extract of key principles from the Companies Internal Policy and should not be viewed as a full AML/KYC Policy.
Global rules mandate Platos LTD to put into place efficient internal protocols and systems to thwart terrorist funding, money laundering, illicit drug trafficking, human smuggling, proliferation of weapons of mass devastation, bribery and corruption, and to act accordingly in the face of any kind of suspicious activities from its customers.
The AML/KYC Policy covers the following matters:
- appointing an Anti-Money Laundering Compliance Officer (AMLCO) and making sure that employees know to report any suspicious activity to them;
- identifying the responsibilities of senior managers and providing them with regular information on money laundering risks;
- introducing measures to make sure that the risk of money laundering is taken into account in the day-to-day business operations;
- documenting and updating anti-money laundering policies, controls and procedures;
- training employees on their anti-money laundering responsibilities;
- Promptly responding to all communication from the appropriate authority;
- Forwarding/reporting all sustained suspicions to the appropriate authority.
GENERAL REQUIREMENTS FOR THE COMPANY
Before engaging in any business dealings with a fresh customer, the Company must ensure that a series of steps are taken and performed:
- AML procedures, including customer identification, record-keeping, discovering and monitoring of unusual or suspicious transactions and, as appropriate, internal/external reporting and control;
- ensuring that all employees know and understand their responsibilities and the Company’s procedures;
- ensure that appropriate training is undertaken;
- all relevant requests from outside sources are forwarded directly to the AMLCO.
Whenever the Company solicits information during the registration process on its Website or Mobile platform, it may request from you details such as full name, country of residence, and email address confirmation. This initial step ensures a basic level of identification and helps establish a foundation for the customer relationship.
Also, prior to initiating the first deposit, the Company reserves the right to request additional documentation, such as an identity document in the form of a valid passport or valid national identity document or a combination of the above and in a form acceptable to us. This step is crucial for enhancing the verification process and ensuring the legitimacy of the customer.
To streamline and fortify our identity verification procedures, the Company may utilize external services like SumSub — an all-in-one verification platform designed to assist businesses in meeting compliance regulations worldwide. SumSub employs advanced technologies to verify the authenticity of documents and corroborate the information provided by customers.
ANTI-MONEY LAUNDERING COMPLIANCE OFFICER
The AMLCO is ultimately responsible for implementing regulations concerning Anti-Money Laundering. For the sake of ease of navigating this document ‘Compliance Officer’ and ‘AMLCO’ refer to the same person; however, the specific tasks of each role are different.
As noted above, the AMLCO is a person of authority with access to any and all relevant information for the performance of their duties. You can contact the Company’s AMLCO department via email: [email protected].
The constant monitoring of the clients’ accounts and transactions is an imperative element in effectively controlling the risk of Money Laundering and Terrorist Financing. In this respect, the AMLCO shall be responsible for maintaining as well as developing the on-going monitoring process of the Company.
The Company will execute applicable practices and processes by utilizing a risk-oriented approach, aiming to concentrate its efforts in the areas where the potential for Money Laundering and Terrorist Financing appears to be greater.
Further, the AMLCO shall monitor and evaluate the effectiveness of the measures and procedures of this Policy on an on-going basis. The adopted risk-based approach that is followed by the Company and described in the full AML Policy has the following general characteristics:
- Recognizes that the money-laundering or terrorist financing threat varies across clients, countries, services and financial instruments;
- allows the board of directors to differentiate between clients of the Company in a way that matches the risk of their particular business;
- allows the board to apply its own approach in formulation of policies, procedures and controls in response to the Company’s particular circumstances and characteristics;
- helps to produce a more cost-effective and efficient system;
- promotes prioritization of effort and actions of the Company in response to the likelihood of Money Laundering and Terrorist Financing occurring through the use of the Company’s services. The risk-based approach adopted by the Company, and described in the Policy, involves specific measures and procedures in assessing the most cost effective and appropriate way to identify and manage the Money Laundering and Terrorist Financing risks faced by the Company.
The Company is prohibited from transacting with individuals, companies and countries that are under international sanctions. The Company will therefore screen all new and existing clients against the United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists.
The Company does not provide services to persons residing in:
- Bosnia and Herzegovina
- Central African Republic
- North Korea
- British Columbia
- South Sudan
The above list may be updated at any time with or without updating this document by a decision of the Compliance officer.