AML/KYC Policy

1. INTRODUCTION
The purpose of this AML/KYC Policy (Anti-Money Laundering and Know Your Customer Policy) is to mitigate the risks associated with money laundering and other illicit activities at Morabitox. This extract highlights the key principles of the internal policy but does not provide a complete overview. If you would like to review the full document, please contact our customer support.
Both domestic and international regulations mandate Morabitox to establish effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption, and bribery. Additionally, Morabitox is required to take appropriate action in response to any suspicious activities conducted by its customers.
The AML/KYC Policy addresses the following aspects:

• Appointing an Anti-Money Laundering Compliance Officer (AMLCO) and ensuring that employees are aware of their obligation to report any suspicious activity to the AMLCO.

• Clearly defining the responsibilities of senior managers and providing them with regular updates on money laundering risks.

• Providing comprehensive training to relevant employees regarding their anti-money laundering responsibilities.

• Documenting and regularly updating anti-money laundering policies, controls, and procedures.

• Implementing measures to incorporate the consideration of money laundering risks into the day to-day operations of the business.

• Forwarding and reporting all suspicions of money laundering to the appropriate authority.

• Promptly responding to all communications from the relevant authority.

2. GENERAL PRINCIPLES
Prior to executing any transaction for a new Customer, the company must establish and implement several procedures:

• AML procedures, which involve verifying the Customer's identity, maintaining records, detecting and monitoring unusual or suspicious transactions, and reporting and controlling them internally as necessary.

• Ensuring that employees are aware of their responsibilities and familiar with the company's procedures.

• Conducting appropriate training for relevant employees.

• Directly forwarding any relevant requests from external sources to the Anti-Money Laundering Compliance Officer (AMLCO).

3. IDENTITY VERIFICATION
When the company receives supporting documents regarding the identity of a new Customer, it is crucial to ensure that these documents adequately prove the existence of the Customer as a genuine individual or legal entity and verify their claimed identity. While the company may utilize third-party sources to assist with fact-checking during the Customer onboarding process, it retains the legal responsibility to ensure that the verification process meets the necessary standards.
The collection, storage, sharing, and protection of the Customer's identification information will strictly adhere to the company's Privacy Policy and comply with relevant regulations that align with the requirements of the General Data Protection Regulation (GDPR).

4. ANTI-MONEY LAUNDERING COMPLIANCE OFFICER
The AMLCO holds the ultimate responsibility for ensuring compliance with the Anti-Money Laundering (AML) regulations. For the purpose of clarity within this document, the terms "compliance officer" and "AMLCO" refer to the same individual, although their roles may involve distinct responsibilities.
As previously mentioned, the AMLCO possesses the necessary authority and access to all pertinent information required to fulfill their duties effectively.
To reach our AMLCO department, please contact us via email at:
[email protected].

5. MONITORING OF TRANSACTIONS
The continuous monitoring of customer accounts and transactions plays a crucial role in effectively managing the risk of Money Laundering and Terrorist Financing.
In this regard, it is the responsibility of the AMLCO to establish and enhance the ongoing monitoring procedures within the company.

6. RISK ASSESSMENT
The company will implement suitable measures and procedures based on a risk-based approach to concentrate its efforts on areas with a comparatively higher risk of Money Laundering and Terrorist Financing.
Furthermore, the AMLCO will continuously monitor and assess the effectiveness of the measures and procedures outlined in this Policy.
The risk-based approach followed by the company, as described in the Policy, encompasses the following key aspects:

• Recognizes that the threat of money laundering or terrorist financing varies among customers, countries, services, and financial instruments.

• Enables the board of directors to differentiate between customers based on their specific business risks.

• Allows the board to customize policies, procedures, and controls according to the company's unique circumstances.

• Enhances cost-effectiveness within the system.

• Facilitates prioritization of efforts and actions 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, as outlined in the Policy, involves specific measures and procedures to identify and manage Money Laundering and Terrorist Financing risks in a cost-effective and appropriate manner.

7. SANCTIONS
The Company strictly adheres to international regulations and is prohibited from engaging in any transactions with individuals, companies, or countries that are subject to international sanctions. These sanctions are imposed by various international bodies, such as the United Nations, European Union, or other relevant authorities, and are designed to restrict business activities and financial interactions with entities involved in illegal activities or posing a threat to international peace and security.
To ensure compliance with sanctions requirements, the Company maintains robust systems and processes to screen customers, counterparties, and transactions against relevant sanction lists and watchlists. These lists include individuals, entities, and countries that are subject to sanctions due to their involvement in activities such as terrorism, money laundering, human rights violations, or proliferation of weapons of mass destruction.
If any customer, counterparty, or transaction is found to be in violation of international sanctions, the Company will take immediate action to cease the transaction and report the incident to the appropriate regulatory authorities. Compliance with sanctions is a critical aspect of the Company's risk management framework, and all employees are trained and obligated to adhere to these requirements.
By diligently enforcing sanctions regulations, the Company actively contributes to global efforts to combat illicit activities and maintain the integrity of the financial system.

8. PROHIBITED COUNTRIES
The Company strictly adheres to international regulations and legal requirements concerning money laundering risks and the provision of its services. As part of these obligations, the Company has implemented measures to ensure that it does not provide services to individuals residing in certain countries that are associated with heightened money laundering risks or where the provision of its services is deemed illegal or prohibited.
These countries are determined based on various factors, including but not limited to the assessment of international organizations specializing in anti-money laundering efforts and the identification of jurisdictions where the Company's services may be susceptible to misuse or abuse for illicit purposes.
The full list of prohibited countries is detailed in the complete version of the Anti-Money Laundering Policy, which can be obtained by requesting it from the Company. It's important to note that this list is subject to updates and revisions in accordance with the decisions made by the Anti-Money Laundering Compliance Officer (AMLCO) or other designated authorities within the Company. Any changes to the prohibited countries list will be effective upon the update of the policy.
By restricting services to individuals residing in these prohibited countries, the Company aims to mitigate potential risks associated with money laundering and ensure compliance with applicable laws and regulations. These measures further demonstrate the Company's commitment to maintaining the integrity of its operations and safeguarding against the misuse of its services for illicit activities.

9. CONTACTS
If you have any questions or concerns regarding the Anti-Money Laundering and Know Your Customer Policy, or if you need further information or assistance, please feel free to contact our dedicated AMLCO department. You can reach out to us through the following channels:
Email: [email protected]
Our AMLCO department is available to address any inquiries related to the policy, provide guidance on compliance matters, and assist with any issues or suspicious activities that may arise. We encourage you to reach out to us if you have any concerns or require clarification on any aspect of the policy.
Additionally, if you become aware of any suspicious transactions or activities related to our services, we urge you to promptly report them to our AMLCO department. Your vigilance and cooperation in maintaining a secure and compliant environment are crucial in combating money laundering and ensuring the integrity of our operations.
We value the trust you place in our company and remain committed to upholding the highest standards of compliance and anti-money laundering practices.