The purposes of the Fearless Solution Anti-Money Laundering and Counter-Terrorist Financing is to identify, prevent and mitigate possible risks of Fearless Solution being involved in illegal activity. Financial institutions and closely related entities (such as e.g. cryptocurrency exchanges) often experience attempts of money laundering and terrorist financing. Anti-money laundering (AML) refers to the laws, regulations and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income. Terrorist financing is defined as the process of providing support to individual or group terrorists. Without direct terrorist financing, such activities as fund-raising, use and possession and funding arrangements also fall under the definition of terrorist financing. Fearless Solution pays thorough attention to any activities that may be considered as money laundering or terrorist financing. To comply with international and local regulations, Fearless Solution has implemented effective internal procedures to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery, and to take action in case of any form of suspicious activity from its clients.
- Verification procedure.
- Assessment of risk.
- Risk categories.
- Monitoring of the customer’s activities.
- Reporting of suspicious activities to respective authorities.
Fearless Solution has an assigned Compliance Officer who is responsible for implementation of the Fearless Solution AML policy, including but not limited to the activities listed below.
Verification procedure
Before any customer can access and benefit from Fearless Solution services, the identity of such customer must be verified. To help fight the funding of terrorism and money laundering activities, the law requires all financial institutions to obtain, verify and record information that identifies each person or entity who wants to do business with us. We are required by law to ask you to provide your name, address, date of birth and other information about you, your organization or persons related to your organization that will allow us to identify you before we can do business with you or accept you. Customers that, in the opinion of Fearless Solution, pose a higher risk may be investigated more thoroughly, which may result in requesting additional information and a longer verification period. Fearless Solution reserves the right to verify the identity of the customer on an ongoing basis, especially when identification information has changed or activities appear suspicious (unusual for a particular user). In addition, Fearless Solution reserves the right to request current documents from the customer, even if they have been authenticated in the past. Customer identification information will be collected, stored, shared and protected strictly in accordance with the Fearless Solution Privacy Policy and applicable regulations.
Assessment of risk
In order to meet its obligations regarding Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF), Fearless Solution has adopted a risk-based approach which enables it to identify, assess and understand the money laundering and terrorist financing risks to which it is exposed, and to take appropriate mitigation measures in accordance with the level of risk.
Risk categories:
1. RISK BY CUSTOMERS:
Suspicious factors include, but are not limited to: discrepancies in provided ID documents, fictitious persons, stolen identities, counterfeit ID documents, use of post box addresses, previous financial crime records, terrorist records, wanted persons, missing contact phone numbers, invalid documents, discrepancies in documents provided for legal entities, etc. Politically Exposed Persons (PEPs) include, but are not limited to: individuals holding prominent public functions such as heads of state, heads of government, ministers and deputy or assistant ministers; members of parliament or similar legislative bodies; members of governing bodies of political parties; members of supreme courts, courts of auditors or boards of central banks; ambassadors, chargés d’affaires and high-ranking officers in the armed forces; members of administrative, management or supervisory bodies of state-owned enterprises; directors, deputy directors and board members or equivalent roles in international organizations, excluding middle-ranking or junior officials.
2. RISK BY COUNTRIES:
Anti-Money Laundering directives impose stricter due diligence requirements for business relationships or transactions involving high-risk third countries. These include requirements to obtain additional information about the customer and beneficial owner, sources of funds and wealth, reasons for the transaction, as well as obtaining senior management approval to establish or continue the relationship.
Monitoring of the customer’s activities
To better understand its customers, Fearless Solution performs ongoing and retrospective monitoring in order to detect any attempts of fraudulent or unlawful activity. Fearless Solution monitors all transactions. Each suspicious activity is thoroughly investigated and, if necessary, reported to the relevant authorities or subject to restrictive measures to prevent money laundering or terrorist financing. Fearless Solution may request the user to provide additional information and documents in case of suspicious transactions. Fearless Solution reserves the right to suspend or terminate its relationship with a client if there is reasonable suspicion that the client is engaged in illegal activities.
Reporting of suspicious activities to respective authorities
In accordance with its AML Policy and applicable legal requirements, Fearless Solution will, when necessary, report any activities that may be considered money laundering or terrorist financing to the relevant authorities. Fearless Solution will not disclose any information about such reports and will not respond to inquiries related to them.