AML & KYC Policy

1. It is the policy of Airfinance pro Ltd. (previously Ytf trade Ltd.) and its affiliates, (hereinafter “The Company”) to prohibit and actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. The Company requires its officers, employees and affiliates to adhere to these standards in preventing the use of its products and services for money laundering purposes.

2. For the purposes of the Policy, money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets.

3. Generally, money laundering occurs in three stages. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

4. Each employee of The Company, whose duties are associated with the provision of products and services of The Company and who directly or indirectly deals with the clientele of The Company, is expected to know the requirements of the applicable laws and regulations which affect his or her job responsibilities, and it shall be the affirmative duty of such employee to carry out these responsibilities at all times in a manner that complies with the requirements of the relevant laws and regulations.

5. The laws and regulations include, but not limited to: “Customer Due Diligence for Banks” (2001) and “General Guide to Account Opening and Customer Identification” (2003) of Basel Committee of banking Supervision, Forty + nine Recommendations for Money Laundering of FATF, USA Patriot Act (2001), Prevention and Suppression of Money Laundering Activities Law of (1996).

6. To ensure that this general policy is carried out, management of The Company has established and maintains an ongoing program for the purpose of assuring compliance with the relevant laws and regulations and the prevention of money laundering. This program seeks to coordinate the specific regulatory requirements throughout the group within a consolidated framework in order to effectively manage the group’s risk of exposure to money laundering and terrorist financing across all business units, functions, and legal entities.

7. Each of the affiliates of The Company is required to comply with AML and KYC policies.

8. All identification documentation and services records shall be kept for the minimum period of time required by local law.

9. All new employees shall receive anti-money laundering training as part of the mandatory new-hire training program. All applicable employees are also required to complete AML and KYC training annually. Participation in additional targeted training programs is required for all employees with day to day AML and KYC responsibilities.

PURPOSE

The purpose of this policy is to provide guidance on the Anti-Money Laundering and Know your Client Policy which is followed by the Company in order to achieve full compliance with the relevant anti-money laundering legislation.

The Policy should be read in conjunction with Operations Manual included in the Internal Procedures Manual and the procedures which are followed for account opening.

LEGAL FRAMEWORK

Investment Firms are required to comply with the provisions of the new Anti-Money Laundering Law of 2007 (the “Law” for the purposes of this policy) and the Directive DI144-2007-08 regarding the prevention of Money Laundering and Terrorist Financing. The main purpose of the Law is to define and criminalize the laundering of proceeds generated from all serious criminal offences aiming at depriving criminals from the profits of their crimes.

In accordance with the Law, CIFs are obliged to set out policies and procedures for preventing money laundering activities. Those procedures, which are implemented by the Company, as these are requested by the Law, are the following:

• Identification and due diligence procedures of clients.
• Record keeping procedures in relation to clients’ identity and their transactions.
• Internal reporting procedures to a competent person (e.g. Anti-Money Laundering Compliance Officer) appointed to receive and consider information that give rise to knowledge or suspicion that a client is engaged in money laundering activities.
• Appropriate procedures of internal control, risk management, with the purpose of preventing money laundering activities.
• The detailed examination of every transaction that due to its nature is considered vulnerable to money laundering, and especially for complicated or unusually large transactions and transactions that are taken place without an obvious financial or legal purpose.
• Measures for making employees aware of the above mentioned procedures to prevent money laundering and of the legislation relating to money laundering.
• Provision of regular training to their employees in the recognition and handling of transactions suspected to be associated with money laundering.

POLICY

The provisions of the Law have been adopted by the Company, which introduces procedures and processes that ensure compliance with the Law and Directives issued by CySEC on this matter.

CLIENT IDENTIFICATION AND DUE DILIGENCE PROCEDURES

The Company has adopted all requirements of the Law in relation to client identification and due diligence procedures as follows:
Due diligence procedures are applied in the following cases:

• When establishing a business relationship.
• When carrying out one-off transactions amounting to EUR15.000 (fifteen thousand euro) or more, whether the transaction is carried out in a single operation or in several operations which appear to be linked.
• When there is a suspicion of money laundering or terrorist financing, irrespective of the amount of the transaction.
• When there are doubts about the veracity or adequacy of previously obtained client identification data.

Failure or refusal by a client to submit the requisite data and information for the verification of his/her identity and the creation of his/her economic profile, without adequate justification, constitutes elements that may lead to the creation of a suspicion that the client is involved in money laundering or terrorist financing activities. In such an event, the Company does not proceed with the establishment of the business relationship and considers the necessity whether the anti-money laundering officer is required to report to MOKAS.

The practice to which the Company adheres in order to comply with the requirements of the Law on the subject of the client identification is achieved on a risk-based approach and it is set out below:

CLIENT DUE DILIGENCE PROCEDURE

Client Due Diligence procedure shall comprise the following:

• Identification of the client and verification of the client’s identity on the basis of information obtained from a reliable and independent source.
• Identification of the beneficial owner and taking risk-based and adequate measures to verify his/her identity on the basis of documents, data or information issued by or received from a reliable and independent source. As regards to legal persons, trusts and similar legal entities, taking risk-based and adequate measures to understand the ownership and control structure of the client.
• Obtaining information on the purpose and intended nature of the business relationship.
• Conducting ongoing monitoring of the business relationship including scrutiny of transactions undertaken throughout the course of the relationship to ensure that the transactions being conducted are consistent with the data and information held by the firm in connection with the client.
• Timing of identification
• Client and beneficial owner identification must take place before the establishment of a business relationship or the carrying out of a transaction.
By way of derogation, the verification of the identity of the client and the beneficial owner may be completed during the establishment of a business relationship if this is necessary in order not to interrupt the normal conduct of business and where there is limited risk of money laundering or terrorist financing occurring. In such situation, these procedures shall be completed as soon as practicable after the initial contact.

RENEWAL OF CLIENT IDENTIFICATION

Reviews of existing records must take place on a regular basis, thus ensuring that the documents, data or information held are kept up-to-date. Client due diligence procedures shall be applied not only to all new clients but also at appropriate times to existing clients on a risk sensitive basis.

SIMPLIFIED CLIENT DUE DILIGENCE

Simplified procedures may apply for lower risk clients. More detailed client due diligence measures for lower risk clients shall apply when there is a suspicion of money laundering, regardless of any derogation, exemption or threshold, and not whenever a business relationship is established.

The following types of clients are considered lower risk:
• Credit or financial institutions regulated by the European Directive 2005/60/EC and its relative transposition member countries legislation on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing.

• Credit or financial institutions situated in a third country which imposes requirements equivalent to those laid down by the European Union and are under supervision for compliance with those requirements.
• Listed companies whose securities are admitted to trading on a regulated market of an EU member state and listed companies from third countries which are subject to disclosure requirements consistent with Community legislation.
• Domestic public authorities of EU member states.
• It should be noted that the Company shall gather sufficient information to establish if the client qualifies to be classified as lower risk client.

ENHANCED CLIENT DUE DILIGENCE

The Company should apply enhanced client due diligence measures in situations which by nature can present high risk of money laundering or terrorist financing.

In accordance with the Fourth Appendix of the Directive DI144-2007-08 regarding the prevention of Money Laundering and Terrorist Financing, high risk clients are the following:

• Non face to face customers
• Accounts in the names of companies whose shares are in bearer form
• Trust accounts
• ‘Client accounts’ in the name of a third person
• ‘Politically exposed persons’ accounts
• Electronic gambling/gaming through the internet
• Customers from countries which inadequately apply Financial Action Task Force’s recommendations

More specifically, where the client has not been physically presented for identification purposes, the Company shall take specific and adequate measures to compensate for the high risk, by applying one or more of the following measures:

• Ensuring that the client’s identity is established by additional documents, data or information.
• Supplementary measures to verify or certify the documents supplied, or requiring confirmatory certification by a credit or financial institution.
• Ensuring that the first payment of the operations is carried out through an account opened in the client’s name with a credit institution which operates in a country of the European Economic Area.

Politically exposed persons are individuals who are or have been entrusted with prominent public functions in a foreign country and close associate is someone with a close relationship with the political exposed persons. The Company should adopt the following additional due diligence measures to determine whether a prospective client is a politically exposed person:

• Approval from Senior Management prior to the establishment of a business relationship with the client.
• Take appropriate measures for the establishment of the origin of the client’s assets and the source of funds that are related with the establishment of the business relationship or transaction.
• Conduct enhanced and continuous monitoring of the business relationship
• Anonymous or Numbered Accounts or accounts in fictitious names

The Company is prohibited from keeping anonymous or numbered accounts or accounts in fictitious names. Additionally, the Company pays special attention to any money laundering or terrorist financing threat that may arise from products or transactions that might favor anonymity and takes measures to prevent their use for money laundering or terrorist financing purposes.

DUE DILIGENCE PERFORMANCE BY THIRD PARTIES

The Company is permitted to rely on third parties to meet the requirements for client due diligence. However the ultimate responsibility for meeting those requirements shall remain with the Company which relies on the third party.

RECORD KEEPING PROCEDURES

The Company should keep the following documents and information for use in any investigation into, or analysis, of possible money laundering or terrorist financing by national authorities:

• The name and address of clients and copies or records of official identification documents (like passports, identity cards, or driving licenses).
• The name and address (or identification code) of counterparties.
• The form of instruction or authority.
• The account details from which any funds were paid.
• The form and destination of payment made by the business to the client.
• Business correspondence.
• For client due diligence, a copy of the references of the evidence is required, for a period of at least 5 years after the business relationship with the client has ended.
• For business relationship and transactions, the supporting evidence and records for a period of at least five years following the carrying out of the transactions or the end of the business relationship.

The retention of the documents/data, other than the original documents or their certified true copies that are kept in a hard copy form, may be in other forms, such as electronic form, provided that the Company is able to retrieve the relevant documents/data without undue delay and present them at any time, to the Commission or to MOKAS, after a request. A true translation is attached in the case that the documents/data are in a language other than Greek or English.

COMPLIANCE OFFICER REPORT TO MOKAS

The employees’ reports are evaluated by the Compliance Officer and if it is considered necessary the Compliance Officer notify the Unit for Combating Money Laundering (MOKAS). After the submission of a suspicious report the customers’ accounts concerned as well as any other connected accounts are placed under the close monitoring of the Compliance Officer.

RELEVANT INTERNATIONAL ORGANIZATIONS

On implementing appropriate measures and procedures on a risk based approach, and on implementing the customer identification and due diligence procedures, the compliance officer consults data, information and reports [e.g. customers from countries which inadequately apply Financial Action Task Force’s (FATF), country assessment reports] that are published in following relevant international organizations:

(a) FATF – www.fatf-gafi.org ·

(b) the Council of Europe Select Committee of Experts on the Evaluation of Anti-Money Laundering Measures (MONEYVAL) – www.coe.int/moneyval ·

(c) the EU Common Foreign & Security Policy (CFSP) http://ec.europa.eu/external_relations/cfsp/sanctions/list/consol-list.htm ·

(d) the UN Security Council Sanctions Committees – www.un.org/sc/committees/ ·

(e) the International Money Laundering Information Network (IMOLIN) – www.imolin.org ·
(f) the International Monetary Fund (IMF) – www.imf.org .

CLIENT ACCOUNT OPENING PROCEDURES

Upon the initial client meeting the necessary due diligence procedures, as described above, are applied to ensure all Know Your Client (KYC) policies are adhered to, all documents necessary for proceeding with KYC procedure are provided and the Company may accept the client and proceed to the account opening. Subsequently the client completes the account opening forms indicating all required information. The responsible administrator collects all initial information of the client and forwards it directly to Legal and Compliance Officer and to the Anti-Money Laundering Compliance Officer for examination, review and approval. Following the approval, the administrator records all necessary information into the Company’s software systems and communicates it to the related departments.

The minimum data of information that are collected before the establishment of the business relationship, with the aim of constructing the customer’s economic profile should include the following:

a) the purpose and the reason for requesting the establishment of a business relationship

b) the anticipated account turnover, the nature of the transactions, the expected origin of incoming funds to be credited in the account and the expected destination of outgoing transfers/payments

c) the customer’s size of wealth and annual income and the clear description of the main business/professional activities/operations
The identification documents required for implementing efficiently the KYC procedures are as follows:
KYC documentation for natural persons

Prior to accepting new clients and allowing them to trade with the Company, the following documents shall be obtained for the verification of clients’ identity and the construction of their economic profile:

Applicable to:

Natural persons
Requirements:
• Certified copy of Passport/Driver’s License or other form of identity with photograph included;
• A recent certified proof of home address in the person’s name.
• All documents/certificates must not be more than 4 months old
• Bank account details for settlement purposes;
• Filled out Front Office Questionnaire;
• Approval by two members of the Company’s Executive Committee;
• Letter and Terms of Business or other signed agreement, namely:_________________
• KYC documentation for legal persons

A different identification procedure is followed for corporate clients interested in opening an account with the Company. The documentation that needs to be obtained by the corporate clients for the construction of their economic profile is presented below:

Applicable to:

• Private companies, partnerships, joint ventures
• Requirements:
• Certificate of incorporation and Certificate of Good Standing of the legal person;
• Certificate of Registered Office
• Certificate of Directors and Secretary
• Certificate of Registered Shareholders in the case of private companies and public companies that are not listed in a regulated market of a European Economic Area country or a third country with equivalent disclosure and transparency requirements
• Memorandum and articles of association of the legal person
• A resolution of the board of directors of the legal person for the opening of the account and granting authority to those who will operate it
• In the cases where the registered shareholders act as nominees of the beneficial owners, a copy of the trust deed/agreement concluded between the nominee shareholder and the beneficial owner, by virtue of which the registration of the shares on the nominee shareholder’s name on behalf of the beneficial owner has been agreed
• Documents and data for the verification of the identity of the persons, in accordance with points 10 and 11 hereto, that are authorized by the legal person to operate the account, as well as the registered shareholders
• Copies of its latest audited financial statements (if available), and/or copies of its latest management accounts.
• Personal information on one Director (different verification documentation required for identity and proof of address):
• Copy of his/her Passport (with photograph and signature specimen included).
• 1 recent copy of confirmation of address in the person’s name.
• All documents/certificates must be not more than 6 months old

Personal information on Ultimate Beneficial Owners with 10% beneficial ownership or more (different verification documentation required for identity and proof of address):
• Certified copy of his/her Passport (with photograph and signature specimen included).
• 1 recent copy of confirmation of address in the person’s name.
• All documents/certificates must be not more than 6 months old
• Letter and Terms of Business or other signed agreement, namely:_________________
• KYC documentation for private companies
The due diligence documentation that is required for private companies is indicated below:

Applicable to:

• Unregulated private companies irrespective of jurisdiction;
• Public companies not listed on stock exchanges;
• Unregulated limited liability partnerships

Non-applicable to:

Private companies with bearer shares in issue
Requirements:

• Copy of Certificate of Incorporation, or Certificate of Registration of the Partnership and any Change of Name Certificates;
• Copy of Certificate of Registered Office
• Copy of Certificate of Shareholders / Limited Partners;
• In case the Shareholders/ Limited Partners are other legal entities the following additional documentation is required:
• A legal structure chart showing all intermediate entities up to the Ultimate Beneficial Owners;
• Full legalization documents of the ultimate legal entity which exercises actual control or, in the case of many ultimate legal entity shareholders, of those legal entities that exercise such control. The legalization documents of intermediary holding companies are not required. The term “legalization documents” includes (i) Certificate of Incorporation, (ii) Certificate of Registered Office, (iii) Register of Shareholders, (iv) Register of Directors, (v) Memorandum & Articles, whereas the term “control” applies to direct and indirect ownership of over 50%;

Additional to requirement #8 below, a UBO resolution from the above ultimate legal entity exercising control.
In cases the Shareholders/ Limited Partners are Nominees, additionally the below are required either the Nominee agreement OR a UBO resolution from such Nominee shareholder(s).

• Copy of Certificate of Directors/ General Partners;
• Personal information on one Director/ General Partner (different verification documentation required for identity and proof of address):
• Copy of his/her Passport (with photograph and signature specimen included).
• 1 recent copy of confirmation of address in the person’s name.
• All documents/certificates must be not more than 6 months old
• Copy of the Memorandum & Articles of Association or Limited Partnership Agreement
• Latest Audited Financial Statements (prepared and signed by Auditors)
• Resolution signed by a Director (whose personal details are disclosed to us) naming the Ultimate Beneficial Owners with 10% or more and % of their beneficial ownership in the Company
• World Check Search
• Personal information on Ultimate Beneficial Owners with 10% beneficial ownership or more (different verification documentation required for identity and proof of address):
• Certified copy of his/her Passport (with photograph and signature specimen included).
• 1 recent copy of confirmation of address in the person’s name.
• All documents/certificates must be not more than 6 months old
• Copy of the list of authorized Signatories with signature specimens (Authorized by a Director/ General Partner whose name and position can be seen in the documents provided to us).
Authorized signatories for trading and back office purposes should also be included.
• If applicable, a Certified copy of a Power of Attorney for the person(s) who will be opening the account (in case this person isn’t a Director).
• Personal information of Attorney/s (different verification documentation required for identity and proof of address):
• Copy of his/her Passport (with photograph and signature specimen included).
• 1 recent copy of confirmation of address in the person’s name.
• All documents/certificates must be not more than 6 months old
• Bank account details of the account through which cash settlement of trades will be taking place.
• Front Office Questionnaire
• Letter confirming that they are trading as Principals.
• Letter and Terms of Business or other signed agreement, namely:_________________
• KYC documentation for private companies with bearer shares
The due diligence documentation that is required for private companies with bearer shares is indicated below:
Applicable:
• Private companies with bearer shares in issue
• Private companies with the capacity to issue bearer shares as per their M&As
Requirements:
• Apostiled copy of Certificate of Incorporation and any Change of Name Certificates;
• Apostiled copy of Certificate of Registered Office;
• Apostiled copy of Certificate of Shareholders;
In case the Shareholders are other legal entities the following additional documentation is required:
• A legal structure chart showing all intermediate entities up to the Ultimate Beneficial Owners;
• Full legalization documents of the ultimate legal entity which exercises actual control or, in the case of many ultimate legal entity shareholders, of those legal entities that exercise such control. The legalization documents of intermediary holding companies are not required. The term “legalisation documents” includes (i) Certificate of Incorporation, (ii) Certificate of Registered Office, (iii) Register of Shareholders, (iv) Register of Directors, (v) Memorandum & Articles, whereas the term “control” applies to direct and indirect ownership of over 50%;
• Additional to requirement #10 below, a UBO resolution from the above ultimate legal entity exercising control.
• In cases the Shareholders are Nominees, additionally the below are required either the Nominee agreement OR a UBO resolution from such Nominee shareholder(s).
• Apostiled copy of Certificate of Directors;
• Personal information on one Director:
• Copy of his/her Passport (with photograph and signature specimen included);
• 1 recent copy of confirmation of address in the person’s name.
• All documents/certificates must be not more than 4 months old
• Apostiled copy of the Memorandum & Articles of Association;
• A written confirmation by the company’s directors once every year that the shareholding structure has not been altered by the issue of new bearer shares or the cancellation of existing ones;
• Bearer shares declarations depending on whether the Client/ CP has bearer shares already in issue or has registered shares in issue but has capacity as per its M&As to issue bearer shares;
• Latest Audited Financial Statements (prepared and signed by Auditors);
• Resolution signed by a Director (whose personal details are disclosed to us) naming the Ultimate Beneficial Owners with 10% or more and % of their beneficial ownership in the Company;
• Personal information on Ultimate Beneficial Owners with 10% beneficial ownership or more:
• Certified copy of his/her Passport (with photograph and signature specimen included);
• 1 recent copy of confirmation of address in the person’s name;
• Apostiled copy of the list of authorised Signatories with signature specimens (Authorised by a Director/ General Partner whose name and position can be seen in the documents provided to us). Authorised signatories for trading and back office purposes should also be included;
• If applicable, a Certified copy of a Power of Attorney for the person(s) who will be opening the account (in case this person isn’t a Director);
Personal information of Attorney/s:
• Copy of his/her Passport (with photograph and signature specimen included).
• 1 recent copy of confirmation of address in the person’s name.
• All documents/certificates must be not more than 4 months old
• Bank account details of the account through which cash settlement of trades will be taking place;
• Front Office Questionnaire;
In cases of a Client / CP acting on behalf of underlying clients the Best Practice Questionnaire is required;
Letter and Terms of Business or other signed agreement, namely:_________________
KYC documentation for funds from non-approved countries

The due diligence documentation that is required for funds from non-approved countries is indicated below:
Applicable:

Open or closed-end Investment Funds; Occupational Pension Schemes; Exchange Traded Funds (ETFs); Mutual Funds; Unit Trusts; Hedge Funds; Investment Trusts; SICAVs; SICAFs from non-EU or non-Approved countries (the “Funds”);

Subsidiaries / trading vehicles of the above.
If the administrator and manager of the Fund are not regulated or situated in an approved country:

Requirements:
• Proof of regulated status from the non-approved country regulator
• Latest available version of Prospectus/ Offering Memorandum/ Placement Memorandum as applicable;
• Certified copy of Certificate of Incorporation, or Certificate of Registration of the Partnership and any Change of Name Certificates;
• Certified copy of Certificate of Registered Office (not applicable if this is provided through a recent Prospectus or M&As)
• Certified copy of Certificate of Directors / General Partners
• Personal information on one Director / General Partner (different verification documentation required for identity and proof of address):
• Certified copy of his/her Passport (with photograph and signature specimen included).
• 1 recent confirmation of address in the person’s name certified as true copy.
• All documents/certificates must be not more than 6 months old.
• Certified Copy of the Memorandum & Articles of Association or Partnership Agreement as applicable
• Latest Audited Financial Statements (prepared and signed by Auditors)
• Letter provided by the Administrator of the Fund stating that he undertakes all necessary AML/KYC procedures in relation to the Funds clients.
• Certified List of Signatories with signature specimens (Authorized by a Director/ General Partner whose name and position can be seen in the documents provided to us). Authorized signatories for trading and back office purposes should also be included.
• If applicable, a Certified copy of a Power of Attorney for the person(s) who will be opening the account (in case this person isn’t a Director).
• If applicable, personal information of Attorney/s (different verification documentation required for identity and proof of address):
• Copy of his/her Passport (with photograph and signature specimen included)
• 1 recent copy of confirmation of address in the person’s name
• All documents/certificates must be not more than 6 months old
• Bank account details of the account through which cash settlement of trades will be taking place
• Letter and Terms of Business or other signed agreement, namely:_______________
If the manager and administrator of the fund are regulated and situated within an EU or Approved country:

Requirements:
• Proof of regulated/ registered status;
• List of authorized Signatories (duly authorized);
• Latest available version of Prospectus/ Offering Memorandum/ Placement Memorandum as applicable;
• Latest Audited Financial Statements (approved and signed by Auditors);
• Letter and Terms of Business or other signed agreement, namely:_________________
• Name of Administrator and Manager of the Fund
• KYC documentation for regulated funds from EU or approved countries

The due diligence documentation that is required for regulated funds from EU or approved countries is indicated below:
Applicable to:
• Open or closed-end Investment Funds; Occupational Pension Schemes; Exchange Traded Funds (ETFs); Mutual Funds; Unit Trusts; Hedge Funds; Investment Trusts; SICAVs; SICAFs registered/ regulated in EU or Approved countries (the “funds”);
• Subsidiaries / trading vehicles of the above

Requirements:
• Proof of regulated/ registered status;
• List of authorised Signatories (duly authorised);
• Latest available version of Prospectus/ Offering Memorandum/ Placement Memorandum as applicable;
• Latest Audited Financial Statements (approved and signed by Auditors);
• Letter and Terms of Business or other signed agreement, namely:_________________
• Name of Administrator and Manager of the Fund
• KYC documentation for regulated financial institutions from EU or approved countries
The due diligence documentation that is required for regulated financial institutions from EU or approved countries is indicated below:
Applicable to:
• Banks, Credit, Investment, Insurance, Custody or Fund Management Institutions as well as Broker-Dealers from EU or Approved countries;
• Subsidiaries or branches of the above entities

Requirements:
• Proof of regulated status;
• List of authorised Signatories (duly authorised);
• Latest Audited Financial Statements (approved and signed by Auditors);
• Letter and Terms of Business or other signed agreement, namely:_________________
• KYC documentation for regulated financial institutions from non- approved countries

The due diligence documentation that is required for regulated financial institutions from non-approved countries is indicated below:
Applicable to:

• Banks, Credit, Investment, Insurance, Custody or Fund Management Institutions as well as Broker-Dealers from non-EU or non-Approved countries;
• Subsidiaries or branches of the above entities
• Non-applicable to:
• Credit, Investment, Insurance, Custody or Fund Management Institutions where a customised list applies

Requirements:
• Certified copy of Certificate of Incorporation, or Certificate of Registration of the Partnership and any Change of Name Certificates
• Certified copy of Certificate of Registered Office
• Certified copy of Certificate of Shareholders/ Limited Partners
In case the Shareholders/ Limited Partners are other legal entities the following additional documentation is required:

• A legal structure chart showing all intermediate entities up to the Ultimate Beneficial Owners;
• Full legalization documents of the ultimate legal entity which exercises actual control or, in the case of many ultimate legal entity shareholders, of those legal entities that exercise such control. The legalization documents of intermediary holding companies are not required. The term “legalization documents” includes (i) Certificate of Incorporation, (ii) Certificate of Registered Office, (iii) Register of Shareholders, (iv) Register of Directors, (v) Memorandum & Articles, whereas the term “control” applies to direct and indirect ownership of over 50%;
• Additional to requirement #8 below, a UBO resolution from the above ultimate legal entity exercising control.
• In cases the Shareholders/ Limited Partners are Nominees, additionally the below are required either the Nominee agreement OR a UBO resolution from such Nominee shareholder(s).
• Certified copy of Certificate of Directors/ General Partners
• Personal information on one Director/ General Partner:
• Certified copy of his/her Passport (with photograph and signature specimen included).
• 1 recent confirmation of address in the person’s name certified as true copy.
• All documents/certificates must be not more than 4 months old
• Certified Copy of the Memorandum & Articles of Association or Limited Partnership Agreement
• Latest Audited Financial Statements (prepared and signed by Auditors)
• Resolution signed by a Director (whose personal details are disclosed to us) naming the Ultimate Beneficial Owners with 10% or more and % of their beneficial ownership in the Company
• Personal information on Ultimate Beneficial Owners with 10% beneficial ownership or more:
• Certified copy of his/her Passport (with photograph and signature specimen included).
• 1 recent confirmation of address in the person’s name (preferably a utility bill) certified as true copy.
• All documents/certificates must not be more than 4 months old
• Certified List of Signatories with signature specimens (Authorized by a Director/ General Partner whose name and position can be seen in the documents provided to us). Authorized signatories for trading and back office purposes should also be included.
• If applicable, a Certified copy of a Power of Attorney for the person(s) who will be opening the account (in case this person isn’t a Director).
• Personal information of Attorney/s:
• Copy of his/her Passport (with photograph and signature specimen included).
• 1 recent copy of confirmation of address in the person’s name.
• All documents/certificates must be not more than 4 months old
• Bank account details of the account through which cash settlement of trades will be taking place.
• Front Office Questionnaire
• In cases of clients/ CPs acting on behalf of underlying clients the Best Practice Questionnaire is required.
• Letter and Terms of Business or other signed agreement, namely:_________________
• KYC documentation for public companies listed on EU or approved countries’ regulated stock markets

The due diligence documentation that is required for Public Companies listed on EU or approved countries is indicated below:

Applicable to:
• Public companies having their securities listed on Regulated Stock Markets in EU or Approved countries;
• Subsidiaries of the above

Requirements:
• Proof of listed status;
• List of authorized Signatories (duly authorized);
• Latest Audited Financial Statements (approved and signed by Auditors);
• In cases of clients/ CPs acting on behalf of underlying clients the Best Practice Questionnaire is required.
• Letter and Terms of Business or other signed agreement, namely:_________________
• KYC documentation for trusts

The due diligence documentation that is required for trusts is indicated below:
Applicable to:

• Bare Trusts, Discretionary Trusts, Private Trusts, Public (Charitable) Trusts, Purpose Trusts
• Non-applicable to:
• Unit Trusts (i.e. Investment Trusts / Mutual funds) which are regulated (see Funds)
• Occupational Pension Schemes established as trusts which are regulated (see Funds)

Requirements:
• Apostiled copy of the Trust Deed in order to identify the Trust structure;
• KYC of the Beneficiaries
• KYC of the Trustees
• KYC of the Settlors
• Apostiled copy of the list of authorized Signatories with signature specimens (Authorized by a Trustee/ Director of the Trustee whose name and position can be seen in the documents provided to us). Authorised signatories for trading and back office purposes should also be included.
• If applicable, a Certified copy of a Power of Attorney for the person(s) who will be opening the account (in case this person isn’t a Director).
• Personal information of Attorney/s:
• Copy of his/her Passport (with photograph and signature specimen included).
• 1 recent copy of confirmation of address in the person’s name.
• All documents/certificates must be not more than 4 months old

Bank account details of the account through which cash settlement of trades will be taking place.
Front Office Questionnaire
In cases of a Client/ CP acting on behalf of underlying clients the Best Practice Questionnaire is required.
Letter and Terms of Business or other signed agreement, namely:_________________
NOTES:

• Fund Manager: KYC on a Fund is not complete without client identification (KYC) of the Fund Manager. The justification for this is that although Company’s client/ CP is the Fund the control rests with the Fund Manager therefore client identification will be incomplete without the identification of the Fund Manager
• Subsidiaries/ Trading vehicles: In case our client/ CP is a subsidiary/ trading vehicle of a Fund then a proof of such a relationship is required by means of a Shareholders’ Register or Audited Financial Statements or Prospectus.
• Audited Financial Statements: In situations where our client/ CP may not provide their own distinct set of Audited Financial Statements, and providing that our client/ CP is a subsidiary of a parent company, the Consolidated Financial Statements of the parent company can be provided instead.
• Corporate Directors: In cases of Corporate Directors or General Partners (i.e. where the Director/ GP is another legal entity), Proof of Directors of the Corporate Director and copy of the Identity Documents of at least one of the natural Persons who are Directors of the Corporate Director need to be provided instead.
• Umbrella funds / sub-funds / segregated portfolio companies: Where a fund operates a number of sub-funds or segregated portfolios (either through share classes, separately incorporated entities or fund allocations) these can be represented as direct sub-accounts of the parent fund and no additional KYC checks are required for the sub-funds or segregated portfolios (except for authorized signatories if different).
• Occupational Pension Funds: In cases of Occupational Pension Funds we perform KYC on both the employer and the Pension Fund. In such cases the client identification requirements and risk profile of the Pension Fund is the same as the one applicable to the employer.
• Funds at the Pre-investor or Start-up phase: We do not initiate a relationship with a fund which is in the pre-investor or start-up phase. In such cases, interim client identification procedures can commence at the pre-investor or start-up phase, however KYC ‘Approved’ status will only be granted once the final executed copy of the Prospectus/ Offering Memorandum/ Placement Memorandum is submitted.
• Certified (True) Copy means that the person certifying the copy of the document has had sight of the original document at certification and is in a position to certify that the copy is a True and complete copy of the original document. The Company recognizes such certifications when made by independent reputable sources. Such sources indicatively include the Client’s Bank operating in the EU or an Approved Country, the Client’s Legal Counsel, a Solicitor / Lawyer or Public Accountant regulated by a professional body (membership number required), Notary Public, the Police or similar authority. The Company requires that the certification process includes the Authenticator stating his name, capacity / position, signature, date and Official Seal on the documents being certified.
• Proof of address: Proof of address can be demonstrated through any of the following documents: Utility Bill, Bank Statement, Credit Card Statement, Voting Card, Telephone Directory, Tenancy Agreement or other similar 3rd party documentation.
• Apostiled copies: Documents should be apostiled in accordance with the provisions of the Hague Convention.
• UBO resolution signatories: The UBO resolution needs to be signed by either:
• A Director of the Company provided he is not also a UBO or
• An independent solicitor, auditor, Regulated Financial Institution from the EU or an Approved country
• Certification standards: Copies of documents should be certified as true copies if the Client/ CP is from the EU or an Approved country and Apostiled if the Client/ CP is from any other jurisdiction.
• EU or Approved Countries are the countries considered as having equivalent AML/CFT systems to the EU. These countries include Argentina, Australia, Brazil, Canada, Hong Kong, Japan, Mexico, New Zealand, Russian Federation, Singapore, Switzerland, South Africa and the United States.
• Non EU/Approved Countries include all other countries that do not belong in the list mentioned above.

BOARD OF DIRECTORS OBLIGATIONS

The Board of Directors’ obligations in relation to this policy have been set as follows:
To determine, record and approve the general policy principles of the Company in relation to the prevention of money laundering and terrorist financing and communicate them to the Compliance Officer.

To appoint a compliance officer and, where is necessary, assistant compliance officers and determine their duties and responsibilities.
To approve this policy which is communicated to all employees of the Company that manage, monitor or control in any way the customers’ transactions and have the responsibility for the application of the practices, measures, procedures and controls that have been determined.

To ensure that all requirements of the Law are applied, and that appropriate, effective and sufficient systems and controls are introduced for achieving the abovementioned requirement.
To assure that the compliance officer and his assistants (if any) and any other person who has been assigned with the duty of implementing the procedures for the prevention of money laundering and terrorist financing, have complete and timely access to all data and information concerning customers’ identity, transactions’ documents and other relevant files and information maintained by the Company so as to be fully facilitated in the effective execution of their duties.

To ensure that all employees are aware of the person who has been assigned with the duties of the compliance officer, as well as his assistants, to whom they report, any information concerning transactions and activities for which they have knowledge or suspicion that might be related to money laundering and terrorist financing.
To establish a clear and quick reporting chain based on which information regarding suspicious transactions is passed without delay to the compliance officer, either directly or through his assistant.

To ensure that the compliance officer has sufficient resources, including competent staff and technological equipment, for the effective discharge of his duties.
To assess and approve the Annual Report of the compliance officer and to take all action as deemed appropriate under the circumstances to remedy any weaknesses and/or deficiencies identified in the Annual Report.

INTERNAL AUDITOR’S OBLIGATIONS

The Internal Auditor’s obligations in relation to this policy have been set as follows:
To review and evaluate, at least on an annual basis, the appropriateness, effectiveness and adequacy of the policy, practices, measures, procedures and control mechanisms applied for the prevention of money laundering and terrorist financing.

To submit the findings and observations, in a written report form, to the board of directors which decides the necessary measures that need to be taken to ensure the rectification of any weaknesses and/or deficiencies which have been detected. The minutes of the abovementioned decision of the board of directors and the internal auditor’s report are submitted to the Commission within 20 days from the date of the meeting.

ANTI-MONEY LAUNDERING COMPLIANCE OFFICER’S OBLIGATIONS

The Anti-Money Laundering Compliance Officer’s obligations have been set as follows:

• To design the internal practice, measures, procedures and controls relevant to the prevention on money laundering and terrorist financing and to describe and allocate the appropriateness and the limits of responsibility of each department that is involved.

• To develop and establish the customers’ acceptance policy and to submit it to the board of directors for consideration and approval.
• To prepare the policy regarding anti-money laundering and terrorist financing.
• To monitor and assess the correct and effective implementation of the policy.
• To receive information from the employees which is considered to be knowledge or suspicion of money laundering or terrorist financing activities or might be related with such activities. The information is received through “Internal Suspicion Report”.
• To evaluate and examines the information received as per point (e). The evaluation of the information is been done on a report, referred as “Internal Evaluation Report”.
• To notify MOKAS for the suspicion through “Compliance Officer’s Report to the Unit for Combating Money Laundering”.
• To provide guidance to the employees on subjects related to money laundering and terrorist financing.
• Determines the Company’s departments and employees that need further training and education for the purpose of preventing money laundering and terrorist financing and organizes appropriate training sessions/seminars. The training program aims at educating employees on the latest developments in the prevention of money laundering and terrorist financing, including the practical methods and trends used for this purpose.
• To prepare and submit to the Commission the Monthly prevention statement for the prevention of money laundering and terrorist financing.
• To prepare the Compliance Officer’s annual report
• To maintain a registry which includes the reports of points (e), (f) and (g), and relevant statistical information (department that submitted the internal report, date of submission to the compliance officer, date of assessment, date of reporting to MOKAS), the evaluation reports of point (d) and all the documents that verify the accomplishment of his duties specified in the present subparagraph.
• The procedure to be followed by the anti-money laundering compliance officer on a daily/monthly basis is as follows:
• Receives a daily report from members of staff for any suspicion for money laundering transactions
• Examine the reports submitted, if any
• Proceed and inform the Senior Management and advice as to the action to be taken which could:
• Stop the transaction, if this is in process
• Inform the client for the reason of the transaction being cancelled
• Collect the information of the transaction if this has already been executed (in this case the client shall not be notified)
• Report to the appropriate authorities of the transaction as this is required by Law

In addition, the anti-money laundering compliance officer prepares an Annual Report for assessing the Company’s compliance with legal requirements which is submitted for approval to the board of directors, within two months from the end of each calendar year. The Annual Report, after its approval by the board of directors, is submitted to the Commission together with the minutes of the meeting, during which the Annual Report has been discussed and approved. It is provided that the said minutes include the measures decided for the correction of any weaknesses and/or deficiencies identified in the Annual Report and the implementation timeframe of these measures. These minutes and the Annual Report are submitted to the Commission within twenty days from the date of the relevant meeting, and not later than three months from the end of the calendar year.