Company name:
Legal Compliance Officer (LCO) name:
Date Report Compiled:
Reporting Period:
Date of Submission to Senior Management:
Summary of Duties Performed by Appointed LCO:
Are the AML/CFT policy and procedure documents up to date?
YES / NO
Are they adequate to meet the firm’s needs & mitigate financial crime risks?
YES / NO
(a) attraction to AML / CFT of qualified special contractors;
(b) conducting business analytics;
(c) study of applied practice;
(d) lack of ML / FT;
(e) compliance with current requirements of laws and regulations
Are they effective in meeting the regulatory & legal rules & requirements?
YES / NO
Do the existing controls and measures ensure that your firm can identify, assess, monitor and manage money laundering risk?
YES / NO
Are client identification procedures effective and adequate?
YES / NO
Have due diligence checks been completed & retained for all new clients?
YES / NO
Are your Risk Management policies and procedures up to date?
YES / NO
Are they adequate to meet the firm’s needs & mitigate financial crime risks?
YES / NO
Are they effective in meeting the regulatory & legal rules & requirements?
YES / NO
How Many Internal Suspicious Activity Reports (SAR’s) Were Completed?
0
Number of SAR’s Passed to competent authorities in relation to ML/TF issues?
0
Number of SAR’s NOT Passed to competent authorities in relation to ML/TF issues?
0
Were there any breaches of internal AML/CFT policies and/or procedures?
YES / NO
Has appropriate and effective Financial Crime and AML training been provided to all employees and associated personnel?
YES / NO
Have all training materials been reviewed for compliance with current laws, regulations and legislation?
YES / NO
Are employees asked for feedback on the training content and delivery?
YES / NO
What was the date of the last content update/review for training materials?
06/23
Have all staff received the training within the past 6 months?
YES / NO
(a) The ZAM.IO obligation under AML/CFT law;
(b) The consequence of non-compliance with AML/CFT laws;
(c) The money-laundering and financial terrorism risks to which the company is prone
and the consequences of such risks;
(d) How to fulfill the obligations along with identifying, managing, and countering risks;
(e) Penalties to be paid if not complied with the AML laws including terms regarding
employees’ termination, criminal and civil penalties, fines, imprisonment terms, etc.
must also be focused during the training program;
(f) Training employees regarding how to react when they confront any suspicious
transactions or clients;
(g) Describing accountabilities and responsibilities of the employees;
(h) A proper training program must also include case studies based on true
circumstances which may include how the threat was detected and how it was dealt
with proper strategies;
(i) Providing details regarding the activities and areas within a company that may be
highly prone to money-laundering and financial terrorism risk.
Training in the form of lectures, discussions and answering questions from employees.
Is a due diligence checklist and questionnaire used for all new customers?
YES / NO
Are adequate/effective background checks performed on all new customers?
YES / NO
Are adequate/effective background checks performed for all new employees?
YES / NO
Number of current customers categorised as ‘other high-risk’?
0
Are adequate/effective monitoring and audit procedures and controls in place?
YES / NO
Based on the audit and monitoring outcomes, are the AML/CFT controls and measures deemed to be comprehensive and proportionate?
YES / NO
Are transaction monitoring processes adequate and effective?
YES / NO
Have all questions been completed?
YES / NO
Legal Compliance Officer:
Signed:
Print Name:
Vladimir Savichev
Date
June 01, 2023
Have all questions been completed?
YES / NO
Has the content contained in the report been reviewed and considered?
YES / NO
Has approval of any improvement actions been given?
YES / NO
Signed:
Print Name:
Iliya Biniaminov
Title
CEO ZAMZAMTECHNOLOGY LLC
Date
June 01, 2023
ZamZamTecnology LLC (“We”, “ZAM.IO”) is a highly respectable and recognizable organization. It has gained its name and reputation among its competitors and consumers through its commitment to conducting business according to moral, ethical, and legal standards.
ZAM.IO does not allow and tolerate any kind of bribery and corruption.
This Anti-Bribery and Corruption Policy (the “Policy”) discourages and prohibits any kind of bribe or corrupt practice with any kind of stakeholder, including offering, promising, or providing any kind of means or value to any stakeholder, including customer, government official, business partner, or a third party to induce any improper action in relation to our business.
This Policy outlines ZAM.IO's moral and legal responsibility to counter bribery and corruption and provide tools and methods to keep check and balance on such practices.
For the purpose of this Policy, bribery offense includes bribes, kickbacks, extortions, either active or inducement of any kind.
Violation of this Policy is highly discouraged. If any employee of ZAM.IO is found in violation of this Policy can face severe civil and criminal penalties in addition to disciplinary proceedings.
This Policy applies to all the employees, directors, officers, and any third party which is directly engaged with our business. Further, the Policy applies to any subsidiary, branch office, or liaison office of ZAM.IO, regardless of its location.
Employees are strictly advised to obtain approval from ZAM.IO to advance any item of value to any government official or private entity.
Provision of any kind of travel, gifts, cash, or meals to any government official or any person in exchange for any ill gain is prohibited.
Use of donations for any unfavorable gain or to influence any person is strictly prohibited. ZAM.IO will sanction any kind of charitable gesture or donation through the proper procedure.
Sometimes it must be necessary to appropriate funds to promote or demonstrate ZAM.IO software, products or services, but it must not be used to influence the normal functioning of such officer. Before appropriating such funds, approval from the concerned department is necessary.
It is strictly prohibited to employ any government official, employee of a private entity, or their relatives to influence or gain an undue benefit. If the employment of such a person is necessary, prior approval of ZAM.IO's legal counsel is necessary.
Political contributions advanced to influence government officials are strictly prohibited. All political contributions will go through the proper channel outlined in a separate policy.
Third parties associated with ZAM.IO, either directly, are strictly prohibited from making any corrupt practice on behalf of ZAM.IO.
All payments to third parties in exchange for their services and contributions to ZAM.IO must be recorded appropriately and evidenced. Additionally, third parties interacting with a government official on behalf of ZAM.IO must be documented.
All third parties are obligated to do due diligence before engaging with government officials on behalf of ZAM.IO.
To ensure compliance with this Policy, ZAM.IO may conduct periodic audits of ZAM.IO. All employees, directors, officers, and stakeholders are obligated to cooperate with the audit process.
All directors, officers, employees, and stakeholders are obligated to report any violation of this Policy to ZAM.IO's legal team. Failure to report such an incident constitutes a violation of this Policy and leads to disciplinary action.
ZAM.IO senior management (CEO) has approved this Anti-Bribery and Corruption Policy in writing as reasonably designed to achieve and monitor our firm’s ongoing compliance with the requirements of the legal regulations.
Date: June 01, 2023
Signature:
/s/ Iliya Biniaminov
CEO: ILIYA BINIAMINOV
This Anti-Money Laundering & Know Your Customer (KYC) Policy (“Policy”) confirms ZamZamTecnology (“We”, “ZAM.IO”) commitment to prevent money-laundering and the financing of terrorism in its business practices and Customers' transactions using ZAM.IO services and products.
This Policy directed to declare of ZAM.IO procedures to combat the following illegal activities:
(a) Money Laundering (“ML”) is conducting or attempting to conduct a financial transaction knowing that the transaction is designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of specified unlawful activities.
(b) Terrorist financing (“FT”) is conducting or attempting to conduct a financial transaction for terrorist activity, meaning as the provision or collection of funds, by any means, directly or indirectly, with the intention that they are used or in the knowledge that they are to be used, in full or in part, in order to carry out any of the offenses within the meaning of the law. This activity is done by intentionally killing, seriously harming, or endangering a person, causing substantial property damage that is likely to seriously harm people, or by seriously interfering with or disrupting essential services, facilities, or systems
ZAM.IO has established Know Your Counterparty (KYC) procedures to combat ML and FT as it is required from banks and other financial institutions. These procedures allow identify every entity (individual / business) that ZAM.IO deal with, to understand the legitimacy of our business relationships, and to identify, and react to unusual or suspicious activity.
ZAM.IO committed to implementing and enforcing effective internal controls to counter ML and FT. The Policy is to apply at a minimum the standards set out in this Policy.
The purposes of this Policy are to:
(i) an effective combating of ML and TF by proper identification of actual Customers and supervision of their transactions; and
(ii) set out the responsibilities of ZAM.IO and its all staff in respect of observing, complying with, and upholding policies on anti-money laundering (“AML”) and counter-terrorist financing (“CTF”); and
(iii) to provide information and guidance to Customers and Third Parties on the money laundering/terrorist financing risks, ZAM.IO KYC procedures, and how to recognise and deal with any potential money laundering/terrorist financing issues if they arise.
ZAM.IO should identify and cease transactions made not only to purchase/sell a cryptocurrency but made mainly to hide the criminal origin of money, finance illegal activity or other unlawful behaviors.
Specific provisions of ZAM.IO policies are confidential and for internal use only, in order to prevent their avoidance by dishonest or fraudulent Customers.
This Policy, procedures, and internal controls are designed to ensure compliance with all applicable AML / CTF regulations and rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures, and internal controls are in place to account for both changes in regulations and changes in ZAM.IO business.
The following words and phrases have the following meanings in this AML/KYC Policy:
Term | Definition |
---|---|
Customer | an agreement (Terms & Conditions) that defines Customers’ rights and obligations when using ZAM.IO Products |
Product | an individual or a business entity that engages in a financial transaction or activity with ZAM.IO and uses ZAM.IO Products |
Account | ZAM.IO as it’s detailed at https://zam.io. The Product includes software (i.e. zMetaboard, ZamWallet iOS and Android application), databases, and services that ZAM.IO offers to Customers through the Product |
KYC | a Customer’s account used by Products. Account allows a Customer to receive ZAM.IO services. Account contains Personal Data and (or) other information about a Customer who uses the Product and has entered the agreement with us |
Terms | Know Your Customer is the process of verifying the identity of a Customer. The objective of KYC is to prevent Products from being used for AML, CFT activities. It also enables ZAM.IO to understand its Customers and their financial dealings to serve them better and manage its risks prudently |
Personal Data | alone or in combination with other information or in certain contexts can be used to identify, distinguish or trace a Customer |
Third party | the third party with who we entered into an agreement and with who we are in a legal relationship. Third parties may provide: remote identity verification, fraud prevention, enforcement of AML/CFT laws and regulations, internal risk management and due diligence procedures, software libraries and SDK, API, technical specialists involved in the development of our Products and other |
(i) We have developed robust internal policies, procedures, and controls designed to comply with applicable laws and regulations, as well as any other reporting requirements and audits.
(ii) This Policy applies to all Customers without any exceptions. ZAM.IO will terminate its involvement with any Customers who fail to comply with this Policy and any employees who violates this Policy.
(iii) The CEO of ZAM.IO, as a senior member of the Management Board, is the main person of ZAMZAMTECHNOLOGY LLC who approves AML / CTF policies and manages AML / CTF activities in the company. The Legal Compliance Officer (“LCO”) is the main person managing the AML / CTF processes at ZAM.IO.
(i) Our Customer Identity Program (“CIP”) is an important part of AML Policy and helps ZAM.IO detect suspicious activity in a timely manner and prevent fraud.
(ii) In order to open an Account and use Products, a Customer’s identity must be verified, authenticated, and checked against government watchlists, including the Office of Foreign Assets Control (“OFAC”). Failure to complete any of these steps will result in Customer’s inability to use Products.
Prior to opening an account for an individual customer, we attempt to collect, verify, and authenticate the following Personal Data:
Prior to opening an account for a business entity, we attempt to collect, verify, and authenticate the following information:
Determination of an individual presence or non-presence on global sanctions lists, PEP lists, watchlists, blacklists, or adverse media (OFAC, UN, HMT, EU, DFT etc.). This check is automated by a Third party. The results of this screening are solely based on potential matches between the user’s Personal Data and the data contained in databases available to a Third Party.
ZAM.IO senior management (CEO) has approved this Anti-Bribery and Corruption Policy in writing as reasonably designed to achieve and monitor our firm’s ongoing compliance with the requirements of the legal regulations.
Date: June 01, 2023
Signature:
/s/ Iliya Biniaminov
CEO: ILIYA BINIAMINOV