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As an operating financial company - we actively counteract money laundering and terrorist financing.

AML - Anti-Money Laundering.

AML Act - Act of 16 November, 2000 on the counteracting of money laundering and terrorist financing.

General Inspector of Financial Information - a government body adequate in cases of money laundering, a body of financial information. It exercises the control over following the regulations regarding counteracting money laundering and terrorist financing.

Obligated institution - a subject obligated to the AML Act. They are for example currency exchange offices, investment companies, insurance companies, investment funds and banks.

Politically Exposed Persons - natural persons in positions such as: heads of state, heads of government, ministers and deputy or assistant ministers, members of parliaments, members of supreme courts, members of the board of central banks, ambassadors who perform or performed these functions publicly, up to one year after the conditions presented in the provisions stopped being met, along with their spouses and those in close professional or economical cooperation, who are residents outside of the Republic of Poland.

Money laundering - an intentional activity, including the exchanging or handling of possessions which is obtained through criminal activity or the participation in such an activity in order to conceal or disguise the illicit origin of the property or of assisting any person who is involved in such an activity to evade the legal consequences of one's action. Is punishable by imprisonment from 6 months to 8 years (Penal Code, section 299).

Measures of financial security applied by the obligated institutions - identification of the client and verifying their identity; identification of the ultimate beneficiary owner, obtaining information regarding the goal of the relation of the client and the obligated unit; running monitoring of the economic relations with the client.

Transaction - payment and withdrawal in a cash or non-cash form, buying and selling currency.

Transaction withholding - temporary prevention from disposing and using money, which is the act of averting concluding the transaction by the obligated institution.

Freeze - prevention of moving, changing and using the possessions or concluding transactions in any form that can change the amount, value, location, ownership, character, destination or any other adjustment that can make it possible to use the possessions.

Money laundering and the financing of terrorism is an international issue, counteracted by countries by applying the regulations defined in the national acts. Despite the fact that the national acts might differ, they are unanimous regarding their key objectives. Their primary aim is to prevent offenders from using the financial system of the country.

In Poland, the Act of 16 November 2000 on counteracting money laundering and terrorist financing is the official document. Additionally, the Regulations of the Minister of Finance are executive orders. The Act describes required duties to be fulfilled by the obligated institutions in order to counteract money laundering and terrorism financing. The Regulations indicate the manner of execution.

At the European level, the regulations addressing counteracting money laundering and terrorist financing are set by the Directive. Financial institutions which operate globally, as we do, are obligated to not only comply with local regulations, but also with the regulations of the countries where they are active.

As a potential customer, during the registration process, personal data is necessary for identification purposes. The submitted data is used to verify the information included in money transfers from the bank, with which you hold your account and with which you will settle your buy / sell currency transactions. In certain cases, for example, when making a transaction including a foreign bank and if you are not a Polish resident, a scan of your identification card/passport may be required. You don't need to worry about the safety of your data - a special effort is made to ensure that they are carefully and efficiently protected from unauthorized access.

If you are already a user, the request for additional information for identity verification may be required at any time, even if it wasn't necessary during registration. Additional transaction clarification may also be requested. This is because of our commitment to monitoring ongoing transactions and assessing risks.

In order to actively prevent money laundering, we use many different forms of protection and control. Know Your Customer Policy is the main security principle that ensures that we know our customers and are able to assess related risks. For this reason, we must identify our users and verify their identity. We also verify sanction list data and establish our user's PEP status’ based on their statements.

All transactions initiated and settled are monitored. When doubts or suspicions about the character of a transaction arise, the transaction will be withheld and a request for further details will be sent. The transaction will only be completed when we are assured that there is no risk of money laundering or any other unlawful actions.

We register every transaction amounting or equalling to 15,000 EUR or higher as suspicious transactions, irrespective of their amount. Linked transactions amounting to less than 15,000 EUR or its equivalent that have been divided into smaller amounts to avoid registration. All registered transactions are sent to the General Inspector of Financial Information.

When a customer’s personal data is found on any sanction list, additional analyses are conducted in order for us to be certain that a business cooperation can be formed. In the case of a confirmed alert on the sanction lists, we will refuse to form a collaboration, and it may be necessary to use the mechanism of freezing property values, or transaction withholding. We are obliged to report such cases to the General Inspector of Financial Information and act accordingly.

During proceedings concerning the suspicion of money laundering or financing of terrorism, prosecutors or the police have the right to request further information, which we are then obligated to provide.

In addition, when we receive information about the criminal character of actions conducted on a customer’s account, the suspicion of committing an offense is reported to prosecutors.

This is due to the financial institutions having an obligation to inform law enforcement about any suspicion of money laundering, fraud or extortion of possessions which could result in our customers becoming victims of a crime. This cooperation between financial institutions and law enforcement significantly contributes to identifying the fraudsters.

Due to the complexity of sanctions imposed by international institutions on certain countries, Cinkciarz.pl identified the following countries using a risk-based approach as those generating unacceptable risks and decided not to pursue business with Syria, Sudan, Cuba, North Korea or Iran.