AML, CFT, KYC Policy

1- Anti -Money Laundering (AML), CFT and Know Your Customer (KYC) Policy

1.1. KLAS FOREX (“KLASFX”) is a Forex and financial institution that continues its commercial life in full compliance with the law.

1.2. Is to establish the general framework by Klasfx to combat money laundering and terrorism financing.

1.3. Klasfx also takes reasonable measures to control and limit the risk of money laundering/terrorism financing, including the allocation of appropriate means.

1.4. KLASFX is committed to high standards of anti-money laundering and counter-terrorism financing (AML/CFT) compliance and aims to ensure that its management and employees comply with these standards in preventing the use of its products and services for money laundering or terrorist financing.

 

2- KLASFX's AML program is designed to be compatible with:

2.1. European and Turkish laws and regulations regarding AML / CFT.

2.2. Directives of the European Parliament and of the Council on preventing the use of the financial system for the purpose of money laundering or terrorist financing.

 

3- MONEY LAUNDERING AND TERRORISM FINANCING

3.1. Money Laundering;

The crime of laundering can generally be defined as any transaction carried out with the aim of hiding the illegal source of the proceeds obtained from the predicate crimes and presenting these proceeds as if they were obtained from a legal source.

The crime of laundering was first defined in our legal system as “Money laundering crime” in Article 2/b of Law No. 4208, which came into force on 19.11.1996. It was later rearranged in Article 282 of the Turkish Penal Code No. 5237, which came into force on June 1, 2006, titled “Laundering of Assets Originating from Crime”.

Laundering acts are specified in detail in international agreements prepared within the scope of combating money laundering. For example, in the 6th article of the United Nations Convention against Transnational Organized Crime , to which Turkey is a party, titled “Criminalization of Laundering Proceeds of Crime”;

Conversion or transfer of property known to be the proceeds of crime for the purpose of concealing or disguising its illicit origin or assisting any person involved in the commission of the predicate offense to avoid the legal consequences of his offence;

Knowing that an asset is proceeds of crime; Concealing or misrepresenting the true nature, source, location, use, movements or ownership or rights to assets.

Subject to the basic concepts of the legal system of the States, knowing that such property is the proceeds of crime at the time of receipt; acquisition, possession or use, participating in the commission or attempt of any of the crimes specified in this article by aiding, abetting, facilitating and guiding in an organized manner or by agreeing to commit a crime.

They are stated as acts of laundering.

3.2. Terrorism financing;

Providing or collecting funds in any way, directly or indirectly, for the purpose of carrying out any terrorist act, in whole or in part, with the intent to use them or with the knowledge that they are intended to be used in any way.


4- AML FUNCTION ORGANIZATION

4.1. CORPORATE ORGANIZATION

Accordance with AML / CFT legislation , KLASFX has appointed responsible persons at the “highest level” among the Board of Directors.

Additionally, an Anti-Money Laundering Compliance Officer is responsible for enforcing the AML policy and procedures of the company.

4.2. POLICY IMPLEMENTATION REQUIREMENTS

Every major change in KLASFX AML policy is approved and carefully monitored by KLAFX’s Board of Directors.

4.3. COMPANY-WIDE RISK ASSESSMENT

Legal regulations regarding the prevention of the use of the financial system for money laundering (ML) or terrorist financing (TF) require financial institutions to take a risk- based approach in combating ML and TF. Risk assessment is a critical component of the KLASFX AML/CFT compliance management program.

As part of its risk-based approach, KLASFX has conducted an AML “Company-wide risk assessment” to identify and understand risks specific to its business. KLASFX AML risk profile is determined after identifying and documenting risks specific to business lines such as the products and services offered by the company, the customers to whom these products and services are offered, the transactions carried out by these customers, and the distribution channels used.

Defining AML/CFT risk categories is based on KLASFX’s understanding of regulatory requirements, legal expectations and industry guidance.

This policy is re-evaluated annually.

 

5- MINIMUM STANDARDS

KLASFX has set standards regarding Know Your Customer (“KYC”). These standards ensure that due diligence is given to each prospective customer before entering into a business relationship by identifying and verifying his/her identity and complying with local and European AML/CFT legislation and regulations on the basis of documents, data or information obtained in a reliable and independent manner. provides.

Interpretation of the KYC policy begins with the identification of the customer with the necessary identification documents. This ID, filled with other collected information, ensures the implementation of the Customer Acceptance Policy.

These objective criteria , there are subjective elements that can raise doubts about a client and require special attention.

Finally, since KYC does not involve static data, but dynamic data resulting from their relationship with the customer, the customer needs to be tracked and constantly monitored.

5.1. CUSTOMER IDENTIFICATION and VERIFICATION (KYC)

Formal identification of customers upon entry into business relationships is a vital element of both anti-money laundering regulations and KYC policy.

In accordance with Article 3 of Law No. 5549, obliged parties are obliged to determine the identities of those who carry out the transaction and those on whose behalf or account the transaction is made, before the transaction is carried out in the transactions made by them and through which they mediate. In this context, ” Principles regarding customer recognition” are regulated in the third section of the ” Regulation on Measures for the Prevention of Laundering Proceeds of Crime and Financing of Terrorism”.

In this context, KLASFX;

By determining and confirming the valid identity and address information of (potential) customers, which are accepted by the legal authorities, before the transaction is established and while the permanent business relationship is maintained.

The income levels of the customers and the commercial activities of the financial services they provide/request are compatible with the general working style and income sources of the customer type they are involved in

It carries out the necessary checks and takes additional measures regarding the possibility of customers being on national/international sanctions lists.

KLASFX does not establish a business relationship and does not perform the requested transaction in cases where it cannot identify the person or obtain sufficient information about the purpose of the business relationship; It terminates the business relationship in case the required identification and confirmation cannot be made due to doubts about the adequacy and accuracy of the customer identification information previously obtained.

The determinations that must be made by our company as a minimum within the scope of standard customer diagnostic measures are listed below:

Identification and confirmation of customer identity, address confirmation, real beneficiary, authorized representatives within the framework of legal legislation and KLASFX internal policies, of customers against the risks of being included in international sanctions lists ( including country risk assessment ).

Determining whether the customer and the parties related to the customer are politically influential or affiliated with politically influential people, the customer and the parties related to the customer are associated with very high risk countries accepted within the scope of international sanctions and KLASFX Internal Policies.

Determining whether someone is acting on behalf and/or on behalf of someone else.

Monitoring customer transactions to detect unusual transactions.

Detection and confirmation of income source.

Receiving information about the reason for working with our company.

Increased customer precautions are also applied to customers who are considered risky by the Company, either during customer acceptance or as a result of a subsequent risk assessment. Regardless of the risk assessment result, taking increased measures and/or updating monitoring activities within the framework of risky customer/transaction/sector evaluations within the scope of national and international legislation and current company practices may be on the agenda.

The determinations that must be made by KLASFX as a minimum within the scope of increased customer measures are listed below:

Identification of the customer, real beneficiary, authorized representative ( including company structure ) and filtering against the risks of being included in international sanctions lists.

Approval of the customer relationship by the relevant business line management/senior management.

Determining the wealth of the customer, the real beneficiary, and confirming it through documents when necessary.

Determining whether the customer’s fund resources and/or capital are easily and satisfactorily verified and, where necessary, confirming them through documentation.

Examining information and documents regarding the reason for working with the company.

5.2. RISK PROFILE IDENTIFICATION

To help determine the level of AML/CFT due diligence to be applied regarding the customer, the “Compliance” risk profile (Low, Medium, High) is first calculated. This calculation is repeated daily.

For this purpose, at KLASFX;

The geographical location where the customer operates (country, region, etc.).

Certain products and services provided to the customer.

Whether the customer has political influence or not.

The customer’s business line or sector in which it operates.

The type of transactions carried out by the customer.

A customer risk assessment methodology is applied that takes into account the customer’s partnership structure, capital and management control.

This methodology is revised by the Company when a new risk is encountered specific to customers and transactions, and KLASFX takes the necessary measures in this regard.

The risk assessment methodology, individuals and institutions whose financial transactions will not be intermediary or for whom increased measures will be taken during the establishment of business relationships are listed below:

Individuals and organizations that avoid providing information and documents and registering.

Individuals and organizations who want to open an account anonymously or with a pseudonym.

Companies with bearer shares (for legal entity members).

Individuals and organizations included in national and international sanctions lists, *Individuals and organizations in risky sectors and professional groups.

Individuals and organizations located or affiliated with countries that do not have adequate regulations regarding the prevention of money laundering and terrorist financing (risky countries).

Signboard companies (Shell companies).

Persons with political influence.

5.3. ONGOING CUSTOMER DUE DILIGENCE

Based review is conducted periodically to ensure that customer-related data or information is kept up to date. The current KYC review process for other categories of customers is based on an “awareness principle”, mainly following the review of a specific file by the AML team.

5.4. ONGOING TRANSACTION MONITORING

Within the scope of preventing money laundering and financing of terrorism, the Company carries out continuous monitoring and control activities for at least the following issues:

Transactions that are not compatible with the customer’s business, funding sources and profile, linked transactions, electronic transfers, newly offered products and services.

In this regard, in order to monitor the services offered by the Company and the transactions it mediates.

Examination through computer-aided programs, media scanning, examination through KLASFX mandatory scanning lists, and special examination activities are carried out. In addition, if the business lines/personnel that provide financial services or mediate the transaction encounter a suspicious situation within the scope of preventing money laundering and terrorist financing during the service/transaction they perform, the relevant individuals and organizations are included in the scope of investigation.

 

6- INTERNAL CONTROL ORGANIZATION

6.1. SUSPICIOUS TRANSACTION REPORT

Suspicious transaction means the assets subject to the transaction made or attempted to be made by or through KLASFX; It is the presence of any information, suspicion or reason to suspect that it has been obtained illegally or used for illegal purposes, or that it has been used for terrorist acts or by terrorist organizations, terrorists or those who finance terrorism, or that it is related or connected with these.

The definition of suspicious transaction includes the illegal acquisition of the asset values subject to the transaction as well as their use for illegal purposes, and thus it is aimed to prevent the financing of terrorism ( including its connection).

The company does not provide information to anyone, including the parties to the transaction, that a suspicious transaction report has been made or will be made to MASAK , except for the information given to the audit staff assigned to audit the liability and to the courts during the trial. This obligation also covers the persons, institutions and organizations that report the suspicious transaction to MASAK, or the members of these people who actually carry out and manage the transaction, or their legal representatives and proxies, as well as other personnel who are aware in any way that a suspicious transaction report has been made.

6.2. RECORDING

KLASFX manages the processes regarding the obligation to provide information and documents within the scope of Articles 31, 32 and 33 of the “Regulation on Measures for the Prevention of Laundering Proceeds of Crime and Financing of Terrorism” and takes the necessary measures.

Including training and internal audit ) and transactions in all kinds of environments from the date of issuance, and books and records from the last recording date; It keeps the documents and records related to identification for ten years from the last transaction date and submits them to the authorities if requested.

6.3. EDUCATION

Training activities are planned in coordination with the KLASFX Human Resources and Training Unit to be established and are organized for all KLASFX personnel, on-site (classroom training) or remotely (e-learning programs, reminders and awareness messages), covering the following topics:

Definition and introduction of MASAK.

Internal compliance officer information and suspicious transaction reporting channels.

Concepts of laundering proceeds of crime and financing of terrorism.

6.4. CHECK

KLASFX internal audit mechanism regularly creates reports on AML/CFT activities and presents them to the board of directors.

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