AML and CFT Procedure

CUSTOMER IDENTIFICATION

Customer identification is an essential element of KYC standards. For the purposes of this document, a customer includes:

• The person or entity that maintains an account with Oriental Wallet or those on whose behalf an account is maintained (i.e. beneficial owners);
• The beneficiaries of transactions conducted by professional intermediaries;
• Any person or entity connected with a financial transaction who can pose a significant reputational or other risk to Oriental Wallet.

Oriental Wallet maintains a systematic procedure for identifying new customers and cannot enter into a service relationship until the identity of a new customer is satisfactorily verified.

The customer identification process applies naturally at the outset of the relationship. To ensure that records remain up-to-date and relevant, Oriental Wallet 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.

Oriental Wallet will not accept customers, persons or entities from restricted or sanctioned countries, organizations. Reference points for such reviews include the websites of:

• Financial Action Task Force (FATF);
• United Nations Consolidated Lists;
• EU Sanctions List

Oriental Wallet can be exposed to reputational risk, and should, therefore, apply enhanced due diligence to its operations. Private accounts, which by nature involve a large measure of confidentiality, can be opened in the name of an individual, a commercial business, a trust, an intermediary or a personalized investment with Oriental Wallet.

ON-GOING MONITORING

On-going monitoring is an essential aspect of effective KYC procedures. Oriental Wallet 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 an account’s activity. Without such knowledge, it is likely to fail in its duty to report suspicious transactions to the appropriate authorities in cases where they are required to do so. The extent of the monitoring needs to be risk-sensitive.

For all accounts, Oriental Wallet 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 accounts. Particular attention is paid to transactions that exceed these limits.

TIPPING OFF

• Tipping off is prohibited under the provisions of Law (9) of 2014 and AML Regulations;
• We ensure that our management and employees are aware of, and are sensitive to the data sharing, and consequences of tipping off;
• In case the employee believes or has reasonable grounds to believe that a customer may be tipped off by conducting CDD measures or on-going monitoring, the employee should refer the case to Compliance Officer. The Compliance Officer shall maintain records to demonstrate the grounds for belief that conducting CDD measures or on- going monitoring would have tipped off the customer.
• If an internal Suspicious Transaction Report is sent to Compliance Officer, the employee should not disclose this to the customer or any other person;
• The company should ensure that information relating to internal Suspicious Transaction Reports are not disclosed to any person other than the members of Board of Directors of the company without the consent of the Compliance Officer;
• The Compliance Officer should not accord permission or consent to disclosure of information relating to internal Suspicious Transaction Report to any person, unless Compliance Officer is satisfied that such disclosure would not constitute tipping off;
• Any letters, notices, or requests received from competent authorities, or FIU, or Police these should not be disclosed to any person/customer.

RECORD KEEPING

Oriental Wallet maintains clear standards and policies, on what records must be kept for customer identification and individual transactions. Such practice is essential to permit Oriental Wallet 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 criminal prosecution.

Oriental Wallet is required to keep records for a period no less than five (5) years as prescribed by law. The five-year period is calculated following the end of the business relationship.

The following records must be kept:

• 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 accounting books.
• Relevant documents of correspondence with the customers and other persons with whom they keep a business relation.

All documents and information are available rapidly and without delay to the authorities for the purpose of discharging the duties imposed on them by the law. The Compliance Officer needs to be able to compile a satisfactory audit trail. Document retention may be in original documents or certified true copies 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.

When setting up document retention policies, Oriental Wallet considers the statutory requirements and the potential needs of the unit. Documents and information must be original or true copies. In cases where the documents are being certified by another person and not Oriental Wallet, or the third party, then the documents must be notarized.

RISK MANAGEMENT

Effective KYC procedures embrace routines for proper management oversight, systems and controls, segregation of duties, training and other related policies. The board of directors of Oriental Wallet is fully committed to an effective KYC programme and procedures that ensures their effectiveness.

Explicit responsibility is allocated within the organization for ensuring that Oriental Wallet’s policies and procedures are managed effectively and are in accordance with local supervisory practice. The channels for reporting suspicious transactions are clearly specified and communicated to all personnel.

Oriental Wallet regularly updates its electronic systems to modern rules and regulations which are developed for a more sophisticated risk check in order to trace money laundering and other criminal financial practices.

Oriental Wallet maintains an ongoing employee training program so that the staff are adequately trained in KYC procedures. The timing and content of training for various staff categories is adapted by Oriental Wallet for its own needs.

ADDITIONAL INFORMATION NOTICE

ORIENTAL WALLET AT ANY TIME CAN INQUIRE AND OBTAIN ADDITIONAL DOCUMENTS AND INFORMATION IF REQUIRED.

IF AT ANY LATER STAGE ANY CHANGES OCCUR IN THE STRUCTURE OF THE OWNERSHIP STATUS OR TO ANY DETAILS, THE CUSTOMERS HAS TO INFORM ORIENTAL WALLET AND PROVIDE ANY NEW INFORMATION AND DOCUMENTS.

IF IN THE COUNTRY OF THE POTENTIAL/EXISTING CLIENT ANY OF THE REQUIRED DOCUMENT DOES NOT EXIST IN THE FORM REQUIRED BY ORIENTAL WALLET THE COMPLIANCE OFFICER MAY ACCEPT A SIMILAR DOCUMENT SERVING THE NEEDS OF DUE DILIGENCE.

Last Updated: March 6, 2023