The latest update 1.02.2025ISTOKS LLC TIN 7720872640 , the owner (https://SPUTIN.com / hereinafter referred to as the “Website/The application”), strives to support effective prevention and detection measures to assist law enforcement agencies in the fight against financial crime. The Website has adopted a strict set of policies and procedures to fulfill the legal obligations of the website in accordance with current anti-money laundering and terrorism legislation.
Background informationMoney laundering is a process, including any action or attempt to commit an action in which money and property (assets) obtained as a result of criminal activity are disguised as coming from a legitimate source. In fact, money laundering is a process in which "dirty money" obtained as a result of criminal activity turns into "clean money", the criminal origin of which is difficult to trace. There are three recognized stages in the money laundering process.
The money laundering process consists of three stages:
• Placement involves the placement of proceeds from crime in the financial system.
• Dissemination involves the transformation of proceeds from crime into another form and the creation of complex levels of financial transactions to complicate control and conceal the source of income and ownership of their Instruments.
• Integration involves the return of laundered income to the economy. Creating an idea of legality.
Money laundering begins with the proceeds of crime from the main crime. The main crime includes, but is not limited to, tax evasion, drug trafficking, bribery, fraud, forgery, murder, robbery, counterfeiting, securities manipulation and copyright infringement. A money laundering offence may include property or income derived from illegal activities.
Terrorist financing is when you knowingly collect or provide property, such as cash, directly or indirectly to terrorists. The main purpose of terrorist activity is to intimidate the population or force the Government to do something. Terrorists need financial support to carry out terrorist activities and achieve their goals. Many of the methods used for money laundering are also used in the framework of terrorist financing, including, but not limited to, concealment of funds and the use of third parties. They need to disguise their money as coming from another source and transfer it into a form that cannot be easily tracked so that it can be used.
1. Main objectives1. Clients' identities are satisfactorily verified in accordance with the firm's risk-based approach before the Website starts a business relationship with them.
2. The website knows its customers and understands their reasons for doing business with us both at the customer acceptance stage and throughout the entire business relationship
3. Our employees are trained and aware of both their personal legal obligations and the legal obligations of the Website
4. Our employees are trained to be vigilant against actions in which there are reasonable grounds for suspicion of possible money laundering, and to report this to the compliance officer
5. A sufficient number of records are stored during the required period
6. We establish, maintain and implement appropriate procedures to achieve these goals
2. General principles1. Anti-money Laundering Policy
The Website has implemented policies, procedures and controls aimed at deterring criminals from using the website to launder proceeds of crime. These policies and procedures are tailored to the risk posed by individual clients.
2. Comprehensive Customer Verification (CDD)
The Website has established customer due diligence procedures to identify users of its services and, in relation to higher-risk customers, the main beneficial owners and sources of funds. These procedures include knowing the nature of our clients' business and being ready for non-standard transactions
To summarize, the Website has adopted its CDD policy to successfully accomplish the following:
- identification and verification of the applicant for business;
- identification and verification of the beneficial owner, where applicable;
- identification and verification when the applicant for business does not act as a principal;
- obtaining information about the purpose and intended nature of the business relationship;
- conducting continuous monitoring of business relations;
- identification of the source of wealth and the source of financing;
- developing a customer acceptance policy and ensuring that a candidate for business meets the requirements set out in such a policy;
- The Website is strictly prohibited from maintaining anonymous accounts or accounts under fictitious names.
3. Suspicious transactions
Unexplained or abnormal transactions, or activities that are suspected to be related to criminal activity, will be immediately reported to the compliance Officer in writing, who will determine whether to report suspicions to the appropriate law enforcement agencies.
4. Training
All staff should be informed of their individual and collective responsibilities and the anti-money laundering policy of the website. Staff are trained to understand the vulnerabilities of a website's business, as well as to recognize and report suspicious activity.
5. Accounting
The website keeps records of who has completed the training, as well as the timing and form of the training sessions. We keep all records confirming the identity of our clients for at least 5 years after the termination of the business relationship. We also keep records of any internal reports of suspicion submitted to the compliance officer.
3. Our Responsibilities• Develop a compliance program to ensure compliance with reporting, record keeping and customer identification requirements;
• Follow customer identification rules and keep special records regarding specific transactions;
• Report suspicious transactions, transactions with large amounts of money and information related to terrorist property to the relevant authorities
4. Risk-based approachWhat is risk? - Risk can be defined as the probability of an event and its consequences. Simply put, risk can be considered as a combination of the probability that something may happen and the degree of damage or loss that may result from such an event. In the context of money laundering/terrorist financing (ML/TF), risk means:
• At the national level: threats and vulnerabilities related to ML/FT that threaten the integrity of the financial system and security.
• At the company level: threats and vulnerabilities that expose the Company to the risk of being used to promote ML/FT All clients have low risk by default, EXCEPT WHEN risk factors are present, such as; Automatic high risk characteristics – if any of the following flags are present, the client belongs to the high risk group.
• A politically significant person
• A client who has been notified of a suspicious transaction, terrorist financing
• A client who is an identified terrorist
• A client for whom we cannot obtain information about the beneficial owner
• A client from a high-risk country
Customer characteristics, product, service, delivery channel:
• A politically significant person, the head of an international organization and close associates;
• Unknown source of funds;
• Large transaction Orders (ETFs) from/to high-risk foreign jurisdictions;
• Participation of third parties without reasonable justification;
• Profession – high-risk professions (for example, a business with a large amount of cash, offshore business, business in high-risk countries, online gambling);
• The client's business structure or transactions seem unusually complex;
• Non-personal identification of the client without a valid reason.
Geography:
• The client is located outside the local or regular client area;
• The client lives in a well-known criminal area;
• The client conducts offshore business activities, client relations with high-risk countries.
Other indicators of suspicious transactions:
• The volume / timing/ complexity of transactions incompatible with the personal/business activity of the client and/or the purpose of the services / account;
• The cost of deposits/transfers incompatible with the profession or source of funds;
• The presence of any signs of suspicious transactions
5. Indicators of suspicious transactions or high-risk potential customersBelow are some examples of some common and industry-specific indicators that may lead you to reasonably suspect that a transaction is related to a money laundering or terrorist financing crime. The presence of one or more of these factors does not indicate that the transaction is suspicious and more careful attention should be paid to this.
General indicators. Below are some examples of common indicators that may lead us to suspect that the transaction is related to a crime related to money laundering or terrorist financing. It will not only be one of these factors alone, but also a combination of several factors combined with what is normal and reasonable in the circumstances of a transaction or attempted transaction.
• The client admits to involvement in criminal activity or makes statements about it;
• The Client refuses or tries to avoid providing the required information, or provides information that is misleading, vague or difficult to verify;
• The Client provides obviously false documentation, which appears to be forged, modified or inaccurate;
• It seems that the client has accounts with several financial institutions in the same region for no apparent reason;
• The client uses the address repeatedly, but often changes the corresponding name;
• The client has an unusual interest in internal controls and systems;
• The client provides confusing information about the transaction;
• The client makes requests that indicate a desire to avoid reporting;
• The client is involved in an activity unusual for this individual or company;
• The client presents confusing information about the transaction or knows few details about its purpose;
• The client seems to be familiar with the issues of money laundering or terrorist financing;
• The client refuses to show identification documents;
• The client often travels to high-risk countries.
Industry examples
• The Client requests a transaction at a foreign currency exchange rate exceeding the established exchange rate.
• The customer wants to pay a transaction fee in excess of the specified fee.
• The client exchanges currency and requests banknotes of the maximum possible denomination in foreign currency.
• The customer does not know much about the address and contact details of the payee, is reluctant to disclose this information or request a bearer document.
• The customer wants a check issued in the same currency to replace the one being cashed.
• The customer wants to exchange cash for a check, and you usually do not participate in issuing checks.
• The client wants to exchange cash for numerous postal transfers in small amounts for many other parties.
• The client enters into transactions with counterparties in unusual places for the client
• The Client informs that the funds must be received by a third party on behalf of the payee.
• The customer makes large purchases of traveler's checks that do not correspond to known travel plans.
• The customer makes purchases by money transfers in large volumes
6. Limited actions and clientsTo reduce and control the risk of money laundering associated with the client, the Website does not provide services and refuses to open an account to the following clients with an unacceptable level of risk:
1. Individuals engaged in the following personal and/or business activities
• negative information is available about the client, which indicates his possible connection with proceeds from crime, money laundering or terrorism, if the information is obtained from reliable sources such as World Check and government websites;
• Customer funds have previously been frozen or seized in connection with suspected criminal activity;
• reinsurance services when the service provider does not have a proper license and there is no supervision of the service provider;
• the client tries to avoid providing information or conceal his economic activities;
• Illegal trafficking of weapons and ammunition;
• economic activity that must be registered in the form of a legal entity;
• unlicensed intermediary foreign exchange services (such as forex dealers, binary options), as well as other unlicensed investment services; h. the client's transactions or payments are complex, unusually large for the client's economic or personal activities, or unclear in terms of their legal and economic purpose;
• Organization of escort services / activities and/or distribution of erotic / pornographic videos and photos and other related services;
• Cash collection services;
• Financial pyramids;
• Distribution of tobacco and alcohol products.
2. Legal entities engaged in the following personal and/or business activities:
• the client tries to avoid providing information or conceal his economic activities;
• negative information is available about the client, which indicates his possible connection with proceeds from crime, money laundering or terrorism, if the information is obtained from reliable sources such as World Check and government websites;
• Customer funds have previously been frozen or seized in connection with suspected criminal activity;
• reinsurance services when the service provider does not have a proper license and there is no supervision of the service provider;
• Illegal trafficking of weapons and ammunition;
• investment services and ancillary investment services when the service provider does not have a proper license in the European Economic Area or in another country where the legal requirements for combating money laundering and terrorist financing are equivalent to the legislation of the European Union;
• legal entities that are recognized as shell companies;
• organization of unlicensed gambling services;
• the reason for the client's creation of a legal entity is unclear, and information about the client of 6 legal entities and information about the client's economic goals are vague and ambiguous;
• unlicensed intermediary services for the exchange of foreign currency (such as forex dealers, binary options);
• the client's transactions or payments are complex, unusually large for the client's economic or personal activities, or unclear in terms of their legal and economic purpose;
• Organization of escort services / activities and/or distribution of erotic / pornographic videos and photos and other related services;
• Financial pyramids;
• Distribution of tobacco and alcohol products
According to the internal AML procedure, customers have two risk categories, i.e. low-risk customers and high-risk customers. For high-risk clients, it is necessary to perform an EDD
A high-risk client is someone who:
• who is a politically significant person, a member of his/her family, or a close employee;
• financial claims to which and the obligations arising from them exceed $ 10,000;
• who has a previous criminal record known to the Website.
7. Monitoring of suspicious activityThe website's AML policy includes due diligence of customers and beneficial owners, as well as ongoing AML monitoring and AML reporting policy. At various times, the Website may request information about transactions made through the customer's account opened on the Website and about the parties to the corresponding payment. If the customer may respond insufficiently or late, the Website also reserves the right to reject any relevant payments in accordance with the requirements of applicable anti-money laundering laws and regulations.