AML/CTF POLICY

The purpose of preventing money laundering and the financing of terrorism at GlolinkOTC s.r.o. is to identify, prevent, and mitigate the risks associated with GlolinkOTC s.r.o. We strongly disavow any involvement in illegal activities and adhere to strict regulations related to such matters.

Financial institutions and closely related entities (such as e.g. cryptocurrency exchanges) experience often 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 falls under the definition of terrorist financing.

GlolinkOTC s.r.o., pays thorough attention to any activities that may be considered as money laundering or terrorist financing. To confirm with international and local regulations, GlolinkOTC s.r.o. 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.

“GlolinkOTC s.r.o. has the assigned Compliance officer who is responsible for implementation of GlolinkOTC s.r.o. AML policy, including but not limited to, of the below listed activities.”

Verification procedure

Before any customer can access and benefit of GlolinkOTC s.r.o. services, identity of such customer has to 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 trade 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 GlolinkOTC s.r.o. pose higher risk may be investigated more thoroughly which may result in requesting of additional information and taking longer term for verification of the identity of such customer.

GlolinkOTC s.r.o. reserves the right to verify the identity of the customer on an ongoing basis, especially when its identification information has been changed or its activities appear suspicious (unusual for a particular User). In addition, GlolinkOTC s.r.o. reserves the right to request from the customer current documents, even if they have been authenticated in the past.

Customer’s identification information will be collected, stored, shared and protected strictly in accordance with GlolinkOTC s.r.o. Privacy Policy and related regulations

Assessment of risk

In order to meet its obligations regarding Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF), GlolinkOTC s.r.o. has adopted a risk-based approach which enables to identify, assess, and understand the money laundering and terrorist financing risk to which GlolinkOTC s.r.o. is exposed, and take the appropriate mitigation measures in accordance with the level of risk.

Risk categories

– Risk By Customers:

Suspicious facts such as but not limited to the: discrepancies in provided id documents, fictitious person, stolen identity, counterfeited id document, post box home address, pervious financial crime record, terrorist record, wanted person, no contact phone number, not valid documents, discrepancies in provided documents for the legal person, etc.

PEPs such as but not limited to the: prominent public functions: head of state, head of government, minister and deputy or assistant minister; a member of parliament or of a similar legislative body, a member of a governing body of a political party, a member of a supreme court, a member of a court of auditors or of the board of a central bank; an ambassador, a chargé d’affaires and a high- ranking officer in the armed forces; a member of an administrative, management or supervisory body of a state-owned enterprise; a director, deputy director and member of the board or equivalent function of an international organization, except middle-ranking or more junior officials.

– Risk By Countries:

Anti-Money Laundering Directive imposes stricter due diligence requirements for business relationships or transactions that involve high-risk third countries. These include requirements to obtain additional information on the customer and beneficial owner, sources of funds and wealth, reasons for the transaction as well as a requirement to obtain senior management approval in order to establish or continue the relationship.

Monitoring of the customer’s activities

To get to know its customers, GlolinkOTC s.r.o. performs ongoing and retrospective monitoring in order to catch any attempts of fraudulent, illegal or unlawful activity.

– GlolinkOTC s.r.o. will monitor all transactions. Each suspicious activity will be thoroughly investigated and, if necessary, reported to the respective authorities or other restrictive measures taken to ensure no money laundering or terrorist financing activity is performed.

– GlolinkOTC s.r.o. will request the User to provide any additional information and documents in case of suspicious transactions.

– GlolinkOTC s.r.o. will suspend or terminate work with a client if there is reasonable suspicion that such a client is engaged in illegal activities.

Reporting of suspicious activities to respective authorities

Following its AML Policy and the applicable legal acts, GlolinkOTC s.r.o., when necessary, will report to the respective authorities of the activities that may be considered as money laundering and terrorist financing. GlolinkOTC s.r.o. will not disclose any information about such report to have been made and will not address any questions in relation to that.

AML/CTF POLICY

AML/CTF POLICY

Verification procedure

Assessment of risk

Risk categories

Monitoring of the customer’s activities

Reporting of suspicious activities to respective authorities

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