KYC POLCY

APN KNOW YOUR CUSTOMER (KYC) POILCY

                            APPLICATIONS PROGRAMMING NETWORK (APN), KNOW YOUR CUSTOMER (KYC) POLICY:

Applications Programming Network (APN) as a parent Company, her corporate KYC Policy is absolutely applicable to her subsidiary companies, brands, products and services such as planetoffices.com and others.

Know Your Customer (KYC) as a business function has become increasingly important Worldwide to prevent money laundering, terrorism financing, identity theft and financial fraud.

Despite KYC significantly improves risk management and reduces losses, Anti-Money

Laundering (AML) non-compliance can also be expensive, as regulatory agencies have begun imposing high fines on organizations they accuse of insufficient AML practices.

Counterparty risk management and KYC and AML regulatory compliance is emerging as one of the most important priorities for companies and financial institutions globally.

In the next five years, according to a recent industry reports, more than 15 percent of

IT budgets of companies and organizations are expected to be focused on the financial crime prevention and risk management technology, primarily in the areas of authentication and identity management, fraud detection and management, customer onboarding and KYC, and transaction monitoring for AML.

While each of these areas is important, customer onboarding and KYC is quickly becoming a critical component of a risk management landscape. The KYC not only entails stringent regulatory oversight from a process perspective, but it also has an impact on the customer experience, especially as an organization embarks on its relationship with a new customer.

 

KYC AS BUSINESS FUNCTION

From an AML perspective, a KYC program is designed to achieve multiple objectives:

 

KYC FROM AML PERSPECTIVE

  • Identify the customer and verify the customer’s identity
  • Understand the customer’s status and associated money laundering risks
  • Assign a risk rating to the customer
  • Allow the organization to perform additional due diligence on higher risk customers, conduct ongoing monitoring of customer risk, and renew due diligence based on changes and activity that is different than expected
  • Make informed decisions about customers based on perceived risks

In general, money laundering is the act of concealing or disguising the true origin of the proceeds of criminal activities so that those proceeds appear to have originated from legitimate sources.

Money laundering occurs in three stages:

Placement stage – the cash generated from criminal activities is converted into monetary instruments or deposited into accounts at financial institutions.

Layering stage – funds are transferred or moved into other accounts or financial institutions to further separate the money from its criminal origin.

Integration stage – funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

In addition to covering applicable substantive laws, the KYC and AML compliance program of each Applications Programming Network (APN),’s Affiliate Company should include guidelines related to selecting and working with its customers. The following sections of the Applications Programming Network (APN), KYC Policy highlight certain key elements that should be included as parts of such guidelines, which serve to further reinforce APN’s KYC Policy and its compliance efforts.

Applications Programming Network (APN) wants to do business only with companies that share our standards of integrity and honorable business practices. Otherwise, we face the possibility that even an arm’s-length association with the third parties who violate the law might harm our reputation or place Applications Programming Network (APN), or its employees in legal difficulty. For these and other reasons, APN’s managers and employees should carefully assess the integrity of potential customers before entering into any business relationship.

 

KYC COMPLIANCE

The following APN’s AML compliance policies and procedures have been derived from the general principles, laws, regulations and directives for combating Anti-Money Laundering.

APN is taking security measures and adopted adequate policies, practices and procedures that promote high ethical and professional standards and prevent the company from being used, intentionally or unintentionally, by criminal elements.

APN has put in place the adequate and comprehensive KYC and AML compliance programs including risk management and control procedures:

 

AML COMPLIANCE

  • Customer acceptance
  • Customer identification
  • On-going monitoring of high risk accounts
  • Risk management

APN is obliged not only to establish the identity of its customers, but also to monitor account activity to determine those transactions that do not conform with normal or expected transactions for that customer or type of account.

APN’s Corporate KYC Policy constitutes core features of risk management and control procedures.8

  • An existing legal entity
  • Credit worthy
  • A reputable enterprise engaged in a legitimate business

All such checks should be documented and repeated periodically, including in the event of any change in control of the customer. The frequency and extent of such checks will vary according to factors such as the nature and extent of the relationship, the level of purchases and the geographic areas where that customer does business.

If there are any suspicious circumstances present or inconsistencies in information, additional due diligence should be undertaken. In any event, however, KYC and AML compliance program of each APN’s affiliate company should require sufficient due diligence to confirm the bona fides of potential customers.

All new customers should be advised of the APN’s KYC and AML compliance expectations. Finally, each APN’s affiliate company should establish a procedure for maintaining appropriate customer records, which may include the following documentation:

A customer approval form detailing the products which the customer is authorized to purchase and the market of intended destination (to be signed by a designated operating company officer)

A policy letter regarding fiscal and trade law compliance (to be sent periodically to remind our customers of our policy).

Due diligence checks which includes (e.g. company search report, details of ownership and principal officers, bank references and other creditworthiness checks) any inquiries from and responses to government agencies regarding the customer or its business.

 

CUSTOMER IDENTIFICATION

APN maintains a regular procedure for identifying new customers and cannot enter into a business relationship until the identity of a new customer is satisfactorily verified.

Procedures document and enforce policies for identification of customers and those acting on their behalf. The best documents for verifying the identity of customers are those most difficult to obtain illicitly and to counterfeit. APN pays special attention in the case of non-resident customers and in no case, short-circuit identity procedure is tolerable just because the new customer is unable to present enough documents and information to satisfy the APN’s KYC rules and due diligence procedures followed.

The customer identification process applies naturally at the beginning of the relationship. To ensure that records remain up-to-date and relevant, APN undertakes regular reviews of existing records. An appropriate time to do so is when a transaction of significance takes place, when customer documentation standards change substantially, or when there is a material change in the way that the account is operated.

However, if the APN’s Compliance Officer becomes aware at any time, through KYC compliance and/or AML reviews, that it lacks sufficient information about an existing customer, he/she will take immediate steps to ensure that all relevant information is obtained as quickly as possible.

APN can be exposed to a reputational risk, and should therefore apply enhanced due diligence in vetting its new and existing customers. At least the APN’s finance or compliance officer must approve all new customers. In case of a new high risk customer, the final decision is taken by the President & CEO of Applications Programming Network (APN).

Particular safeguards have been put in place internally to protect confidentiality of customers and their business. APN ensures that equivalent scrutiny and monitoring of these customers and their business is conducted, e.g. it is available to be reviewed by APN’s compliance officer and auditors.

APN maintains clear and transparent KYC and AML standards and policies, on what records must be kept on the customer‘s identification and individual transactions. Such practices are essential to permit the company to monitor its relationship with the customer, to understand the customer’s on-going business and, if necessary, to provide evidence in the event of disputes, legal action, or a financial investigation that could lead to a criminal prosecution.

As the starting point and natural follow-up of the identification process, APN obtains customer identification papers and retain copies of them for at least five (5) years after an account is closed. The company also retains all financial transaction records for at least five (5) years from the date when APN’s relationship with the customer was terminated or a transaction was completed.

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Latest company, management/investor presentation and detailed activity description

Company organizational chart/structure, including legal entities under effective control of the group and/or of the shareholders Certificate of incorporation Official extract of the register of commerce (or equivalent authority keeping the official register of companies)

Articles of association

APN obtains all information necessary to establish to its full satisfaction the identity of each new customer and the purpose and intended nature of the business relationship.

APN requires all new customers to be approved in accordance with the APN’s Corporate Compliance Policy and APN’s KYC Policy.

Here is the list of documents that are generally required by APN from potential customers.

 

GENERAL IDENTIFICATION REQUIREMENTS

APN obtains all information necessary to establish to its full satisfaction the identity of each new customer and the purpose and intended nature of the business relationship.

APN requires all new customers to be approved in accordance with the APN’s Corporate Compliance Policy and APN’s KYC Policy.

Here is the list of documents that are generally required by APN from potential customers.

  • Latest company, management/investor presentation and detailed activity description
  • Company organizational chart/structure, including legal entities under effective control of the group and/or of the shareholders
  • Certificate of incorporation Official extract of the register of commerce (or equivalent authority keeping the official register of companies)
  • Articles of association.
  • Corporate documents evidencing the full names and shareholding of all beneficial owners, including the names of the owners under any trust structure. (Please note that the beneficial owner must be a business name, public limited company, state owned, or an individual. If the majority shareholder of a company is another privately owned company, further enquiries must take place until the ultimate beneficial owner has been identified)
  • List of the persons authorized to sign for relevant transactions (including copy of their identification document, i.e. passport, and notarized certificate of signature) and corporate documents/power of attorney confirming such signature rights Information on past and present litigations (if no present and/or past litigations, declaration signed by the company’s authorized to sign persons can be accepted).
  • Financial statements and audit reports for the last 2 years (cash flow, balance sheet, loss & profit account)
  • Principal bankers (name of the banks, bank branch address details, name of bank account manager & contact details, reference letters confirming fund availability correspondent to the deals requested)

 

CUSTOMER DUE DILIGENCE AND IDENTITY VERIFICATION PROCEDURES

Customer identification must be carried out as soon as reasonably practicable after first contact is made. Except its obligation to exercise due diligence and customer identification, APN must confirm that the identity info, which it holds for its customers, remains fully accurate and updated with all necessary identifications and information throughout the whole business relationship. APN reviews and monitors the validity and adequacy of customer identification information in its possession on a regular basis.

Notwithstanding the above and taking into account the degree of risk, if realized at any time during the business relationship that there is a lack of sufficient or reliable evidence (data) and information on the identity and financial profile of an existing customer, APN immediately takes all necessary actions using the identification procedures and measures to provide due diligence, in order to collect missing data and information as quickly as possible, and in order to determine the identity and create a comprehensive financial profile of the customer.

Furthermore, APN continuously monitors accuracy of the information about the identity and economic portrait of its customers, especially when and where one of the following events occurred:

A significant transaction that appears to be unusual and/or significant than the usual type of trade and economic profile of the client

A significant change in the situation and legal status of the customer as:

Change of directors/secretary

Change of registered shareholders and/or actual beneficiaries

Change of registered office

Change of trustees

Change of corporate name and/or trade name

Change of main trading partners and/or significant new business

A significant change of operating rules of the client’s account, such as:

Change of persons authorized to handle its account

Request for opening a new account in order to provide new investment services and/or financial instruments

In case of customer transaction via internet, phone, fax or other electronic means where the customer is not present, to verify the authenticity of his/her signature, or that is the person who actually owns the account, or is authorized to handle the account, APN established reliable methods, procedures and practices to control access to electronic means to ensure that it deals with the actual owner or authorized signatory of the customer.

Where the customer refuses or fails to provide APN with the required documents and information for identification and creation of economic portrait, before entering into the business relationship, or during the execution of an individual transaction without adequate justification, APN will not proceed in a contractual relationship or will not execute the transaction.

This can lead to a suspicion that the customer is engaged in money laundering and terrorism financing, and APN will report the customer and transaction to FATF and OFAC. If during business relationship the customer refuses or fails to submit all required documents and information within reasonable amount of time, APN has the right to terminate the business relationship and close the accounts of the customer.

The APN’s compliance officer and legal department will also examine whether to report the case to FATF and OFAC. Key components of customer due diligence and APN’s KYC requirements:

 

CUSTOMER ONBOARDING

Review customer profile and documentation for completeness

Perform customer identification and verification checks

Run AML checks and real- time screening for new customer

Perform enhanced due diligence (EDD) and risk profiling

 

Applications Programming Network (APN) Customer onboarding

Key components of customer due diligence and APN’s KYC requirements:

Check completeness of profile and KYC documentation via gap analysis

Perform customer identification procedures according to applicable guidelines

Identify beneficial shareholders and provide background screening

Provide risk profiling and EDD, if necessary

 

REMEDIATION

Structured database: Sanction screening, bad press, politically exposed person

Unstructured database: Screening through social media sources and through news outlets

SCREENING

On-going customer monitoring is an essential aspect of the effective KYC procedures.

APN can only effectively control and reduce the risk if it has an understanding of normal and reasonable account activity of its customers so that it has means of identifying transactions which fall outside the regular pattern of customer activity.

Without such knowledge, it is likely to fail in its duty to report suspicious transactions to the appropriate authorities in cases where APN is required to do so.

The extent of the monitoring needs to be risk-sensitive. For all customers, APN has systems in place to detect unusual or suspicious patterns of activity. This can be done by establishing limits for a particular class or category of customers. Particular attention is paid to transactions that exceed these limits.

Certain types of transactions alert to the possibility that the customer is conducting unusual or suspicious activities. They may include transactions that do not appear to make economic or commercial sense (big transactions), or that involve large amounts of cash deposits that are not consistent with the normal and expected transactions of the customer.

 

COMPLIANCE MONITORING

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There is intensified monitoring for higher risk accounts. APN has set key indicators for such accounts, taking note of the background of the customer, such as the country of origin and source of funds, the type of transactions involved, and other risk factors.

On an ongoing basis, APN’s managers should maintain a high degree of awareness of our customers’ business practices and be alert to the possibility of detrimental changes in a customer’s business practices, as well as signs of questionable conduct including suspicious transactions.

For example, if a press report alleges that a customer or a customer’s customer is involved in illegal trade practices, or if a customer’s orders suddenly increase dramatically without any clear justification based on market conditions, further inquiries may be appropriate. Any indications of possible violations should be reported to APN’s management and legal department.

 

 

CUSTOMER RELATIONS

 APN respects the commercial freedom of its customers and recognizes that antitrust and competition laws may restrict the extent to which control can be exercised over resale prices or other conditions under which our customers resell our products or services.

Consistent with these and other principles and in accordance with the APN’s Code of Conduct and Corporate Compliance Policy, employees should neither own a substantial interest in a customer or organization seeking to become a customer unless approved in writing by the responsible APN’s manager, nor become involved in directing or managing a customer’s business affairs.

Moreover, in no circumstances should an employee assist any person in any conduct involving our products that violates fiscal, trade or anti-money laundering laws and regulations, including evasion of applicable taxes or import duties. Nor should any employee facilitate or participate in any activity that subverts this KYC Policy, including, for example, by agreeing to interpose an existing or new customer to act as an intermediary purchaser, which will resell APN’s products or services to another firm that has not been approved as a customer. A

We expect our customers to comply with all applicable laws when they resell our products, and we expect that our customers will, in turn, seek to ensure that their customers resell our products in the market of intended destination. We reserve the right to stop supplying products to any customer shown to have been involved in illegal trade or distribution of our products. We expect our customers to do the same in relation to their own customers.

 

RECORD KEEPING

Applications Programming Network (APN) is required to keep records for a period of at least five (5) years by the law. The 5-year period is calculated from the time of finished transactions or the end of business relationship.

 

The following records must always be kept in file:

RECORD KEEPING APPLICATIONS PROGRAMMING NETWORK (APN) COM

Copies of the evidential material of the customer identity

Relevant evidential material and details of all business relations and transactions, including documents for recording transactions in the APN’s accounting books and records

Relevant documents of correspondence with the customers and other persons with whom they keep business relations.

All APN’s documentation and information must always be kept in an ideal order and promptly available to the senior management, audit or authorities’ requests. APN’s documents and information must be originals or certified true copies of documents, and be kept in hard copy, or other format such as electronic form, given that they can be available at any time and without delay.

Applications Programming Network (APN) will retain copies of any SAR or OFAC report filed and all supporting documentation for five (5) years from the date of filing. Pursuant to our confidentiality obligations, we reserve the right to refuse any subpoena requests for SAR or SAR related information and will notify FinCEN immediately of such request.

APN employees should also retain relevant information illustrating their customer’s identity for a minimum of five (5) years. APN’s employees and counterparts should retain copies of any SAR filed or reported to Applications Programming Network (APN) for five (5) years from the date of filing or reporting the SAR.

 

RISK MANAGEMENT

Applications Programming Network (APN) follows effective KYC risk management procedures for proper management, oversight, systems and controls, separation of duties, training and other related policies.

APN designated specific responsible persons for the KYC and AML compliance management to ensure that the company’s policies and procedures are managed effectively and are in accordance with internationals and local compliance practices. The channels for reporting suspicious customers and transactions are clearly specified and communicated to all employees.

If there is clear evidence of fraud or immediate financial loss to Applications Programming Network (APN) but questionable transaction has not yet triggered a match on the SDN list, the transaction should not be processed. Any suspicions should not be conveyed to the customer or its agent. The employee processing a potentially questionable transaction should immediately notify the APN’s Compliance Officer.

Employees should not attempt an investigation on their own. In-depth investigations must be left to the APN’s Compliance Officer and senior management. After an investigation, the Compliance Officer will decide if a SAR or OFAC report should be filed.

It is critical for APN that all employees fully understand the need for and implement KYC and AML policies consistently. A culture that promotes such understanding is the key to a successful KYC Policy implementation

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REPORTING

Applications Programming Network (APN) will monitor several areas through automated internal reports to ensure compliance with this KYC Policy on a weekly basis. APN will first monitor all forms of payment to ensure that the source of funds complies with the APN’s acceptable forms of payment. APN also monitors all transactions to ensure that our products are not being used for money laundering.

 

OFAC Compliance

To protect U.S. and other national interests and security, the Office of Foreign Assets Control

(OFAC) of the U.S. Department of the Treasury identifies countries and individuals considered as hostile. OUR C

As part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific. Collectively, such individuals and companies are called Specially Designated Nationals (SDNs). Their assets are blocked and U.S. persons and businesses are generally prohibited from dealing with them.

Before working with a new customer, Applications Programming Network (APN) will check the SDN list to ensure that a customer or business does not appear on the list and is not from, or engaging in transactions with persons or entities from countries and regions on the OFAC SDN list.

APN will run the name of every individual and business in the company database against the SDN list. This includes any and all entities or individuals associated with

Applications Programming Network (APN). The SDN list will be run each week and a report will be generated at that time.

APN employees under the supervision of the Compliance Officer will review the reports in a timely fashion. Anyone on the report will be investigated by the Compliance Officer and reported to the proper authorities if necessary. This activity will be done in strict confidentiality. This review process shall be conducted on each and every business day a report is run.

If Applications Programming Network (APN) identifies the individual and/or business matching the SDN list or is from or transacting with a person, entity, country, or region on the SDN list,

APN will block the transaction and contact OFAC within one (1) week of discovery.

APN will not resume normal operations with the identified individual and/or business, or proceed with transaction until all necessary steps have been taken and cleared with the OFAC. Different from the Suspicious Activity Report (SAR) regulations, under the

OFAC guidelines, APN may notify the identified individual and/or business that transaction has been blocked.

 

CORPORATE AUDIT

The APN’s Compliance Officer will be responsible for maintaining and overseeing an internal audit process every year or as needed for providing guidance and assistance in the development and implementation of APN’s KYC and AML compliance programs.

The APN’s internal audit department shall conduct a review of the KYC Policy and associated internal programs on an annual basis or as needed.

 

RED FLAGS

Situations that signal possible money laundering activity include:

Customer exhibits unusual concern regarding the APN’s compliance with government reporting requirements and the company’s KYC and AML policies, perhaps with the customer’s identity, or is reluctant or refuses to reveal any information concerning business activities, or furnishes unusual or suspicious identification or business identification.

Customer wishes to engage in transactions that lack business sense or apparent financial strategy, or are inconsistent with the customer’s stated business or financial strategy or needs.

The transfer of the product to an apparently unrelated third party

Little concern by the customer of the purchase price or the buy-back conditions

Information provided by the customer that identifies a legitimate source for funds is false, misleading, or substantially incorrect.

Upon request, the customer refuses to identify or fails to indicate any legitimate source for his or her funds and other assets.

The customer (or a person publicly associated with the customer) has a questionable background or is the subject of news reports indicating possible criminal, civil, or regulatory violations.

The customer appears to be acting as an agent for an undisclosed principal, but declines or is reluctant, without legitimate commercial reasons, to provide information or is otherwise evasive regarding that person or entity.

The customer has difficulty describing the nature of his or her business or lacks general knowledge of his or her industry.

The customer attempts to make frequent or large deposits of currency, insists on only in cash equivalents, or asks for exemptions from the company’s policies relating to the deposit of cash and cash equivalents.

The customer engages in transactions involving cash or cash equivalents or other monetary instruments that appear to be structured to avoid the $10,000 government reporting requirements, especially if the cash or monetary instruments are in an amount just below reporting or recording thresholds.

The customer is from, or has accounts in, a country identified as a non-cooperative country or territory by the Financial Action Task Force (FATF) and OFAC.

The customer’s account has unexplained or sudden extensive wire activity, especially in accounts that had little or no previous activity.

The customer’s account shows numerous cashier’s check transactions aggregating to significant sums.

The customer’s account has a large number of wire transfers to unrelated third parties.

The customer’s account has wire transfers that have no apparent business purpose to or from a country identified as money laundering risk or a financial secrecy haven.

The customer makes a funds deposit followed by an immediate request that the purchase be cancelled with no concern for cancellation fees.

The customer requests that a transaction be processed in such a manner to avoid the company’s normal documentation requirements.

 

GOVERNMENT INQUIRIES

From time to time, APN may be served with legal process or receive written or oral requests for information from law enforcement or other government agencies for records or information about customers or business associates who may be under investigation or who may be associated with a third party that is under investigation.

As set out in the APN’s Corporate Compliance Policy, it is APN’s responsibility to cooperate fully in these inquires within the confines of applicable privacy and other laws and to respond to each lawful request in a timely fashion. Any employee who receives such a request should follow the procedures of the APN’s Corporate Compliance Policy, including immediate reference to the APN’s legal department for review.

In keeping with our long-standing policy of supporting government actions against illegal trading, we are asked from time to time to assist in tracing the country and source of a particular product and our customer for that product based on our other records. Each APN’s affiliate company should have such tracing systems which, with related documentation, will allow us to assist governments with their attempts to identify purchasers of our products, and the dates and locations of production.

Also, any employee who becomes aware of any attempt to tamper with documentation for our products or any attempt to falsify invoices or other import documents should promptly report these occurrences to the legal department.

 

VIOLATIONS

Any indications of possible violations of the APN’s KYC Policy or Corporate

Compliance Policy or of suspicious activity by customers should be reported promptly to the legal department of the relevant APN’s affiliate company for appropriate action.

Actions that may be appropriate include monitoring a customer’s activity, a possible management decision to suspend or sever the business relationship in accordance with APN’s KYC Policy and/or a determination of whether to report the activity to the appropriate government authorities.

The APN’s legal department of each affiliate company shall implement a procedure to ensure that the identify of any person reporting violations of this KYC Policy or Corporate Compliance Policy or any suspicious activity by customers will be kept confidential if the reporter of that information so requests.

Consistent with the APN’s Code of Conduct and legal procedures, any employee who fails to comply with this KYC Policy or the Corporate Compliance Policy, and policies that have been and will be promulgated by the APN’s affiliate companies, may be subject to disciplinary action, which may include termination and loss of employment-related benefits.

Any suspected violations of fiscal, trade or anti-money laundering laws by customers, licensees or contract manufacturers should be reported in accordance with the procedures set out above.

Failure to file a match on the SDN list with the OFAC may lead to substantial civil and criminal penalties. Criminal penalties can include fines ranging from $50,000 to $10,000,000 and imprisonment ranging from 10 to 30 years for willful violations. Civil penalties can include fines ranging from $250,000 to $1,075,000 for each violation.

APN’s employees are urged to consider the spirit of this KYC Policy to act accordingly. It is vital that we maintain our commitment both to observing and abiding by the laws governing our business and to the protection of our good name and reputation. Any questions regarding this policy statement should be referred to the APN’s legal department.

 

PERSONNEL

Applications Programming Network (APN) has appointed the Compliance Officer, who is fully responsible for implementation and on-going execution of all APN’s corporate policies, codes and standards including KYC, and AML programs. The Compliance Officer works as part of the APN’s legal team and reports directly to the President & CEO.

 

COMPLIANCE OFFICER

Ensuring the Company’s compliance with the requirements of the Regulations

Establishing and maintaining internal AML program

Establishing an audit function to test its anti-money laundering and combating the financing of terrorism procedures and systems

Training employees to recognize suspicious transactions

Receiving and investigating internal suspicious activity and transaction reports from staff and making reports to the FIU where appropriate

Ensuring that proper AML records are kept

Obtaining and updating international findings concerning countries with inadequate AML systems, laws or measures.

 

EMPLOYEES

All APN employees, managers and directors who are engaged in the KYC and AML related duties must be suitably vetted. This includes a criminal check done at the time of employment and monitoring during employment. Any violation of this KYC policy and related internal procedures must be reported in confidence to the Compliance Officer, unless the violation implicates the Compliance Officer, in which case the employee must report the violation to the APN’s President and CEO.

 

 

TRAINING

Employees who work in areas that are susceptible to the money laundering or financing terrorism schemes must be trained in how to comply with this KYC Policy or the AML programs. This includes knowing how to be alert to money laundering and terrorism financing risks and what to do once the risks are identified.

Applications Programming Network (APN) provides KYC, AML and Countering the Financing of Terrorism (CFT) training to employees who will be dealing with customers or will be involved in any AML checking, verification or monitoring processes.

The Company may conduct its training internally or hire external third party consultants.

Each person employed within APN is assigned a supervisor who teaches him or her in relation to all policies, procedures, customer documentation forms, KYC/ AML/CFT requirements, etc. There is a training plan for each new employee and tests that are being held for 2-3 months (depending on level within the business).

APN’s KYC and AML training program is aimed to ensure its employees to receive appropriate training level with regards to any possible AML risks. The Company’s AML and risk awareness training includes the following content:

The APN’s commitment to the prevention, detection and reporting of AML and

CFT crimes

Examples of money laundering (ML) and terrorism financing (TF) that have been detected in similar organizations, to create an awareness of the potential ML and TF risks which may be faced by the APN’s employees

Well known or recognized typologies, especially where made available by the FATF or AML supervisors

The consequences of ML and TF for the company, including potential legal liability

 The responsibilities of the company under the AML and other regulations

How to identify and report unusual activity that may be a suspicious transaction or attempted transaction

The rules that apply against unlawful disclosure of suspicious transactions (“tipping off”)

For further information please contact us at:

Email: [email protected]

Website: www.planetoffices.com

 

 

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