AML/KYC POLICY

Win Vision N.V. (hereinafter “Win Vision”) is committed to fully comply with all applicable laws and regulations regarding anti-money laundering procedures.

Win Vision has adopted and will enforce the provision set forth in AML/CFT regulations in order to prevent and detect money laundering or other illegal activities.

If Win Vision its personnel and/or premises are inadvertently used for money launder or other illegal activities, Win Vision could be potentially subject to serious civil and/or criminal penalties. Therefore, it is imperative that every member, officer, director, and employee

 (hereinafter “Employee”) is familiar with and complies with the policy set forth in this document.

To ensure that Win Vision policies and procedures are adhered to, Win Vision shall designate Anti-Money Laundering Compliance Officer (hereinafter “Compliance Officer”).

WHAT IS MONEY LAUNDERING?

Money laundering is illegal process of making large amounts of money generated by a criminal activity, such as drug trafficking or terrorist funding, appear to have come from legitimate source. With respect to entities, any involvement whether it be to instigate, assist, conceal, or ignore the source, nature, location ownership or control of money laundering activities, can lead to both civil and criminal proceedings against both the individual and the entity involved.

Money laundering may involve the proceeds of drug dealings, terrorist activities, arms dealing, mail fraud, bank fraud, wire fraud or security fraud, among other activities.

Money laundering transactions may include:

  • Advising a potential or existing client on how to structure a transaction to avoid reporting and/or record keeping requirements;
  • Engaging in any activity designated to hide the nature, location, source, ownership or control of proceeds of criminal activity;
  • Dealing in funds to facilitate criminal activity;
  • Dealing in the proceeds of criminal activity;
  • Engaging in any activity while wilfully or recklessly disregarding the source of funds or the nature of the client’s transaction;

WHAT IS TERRORIST FINANCING?

Financing of terrorism is illegal process associated with gathering and providing financial or other assets knowing that such assets will be, in full or in part, used to commit criminal offence of terror, terrorist attack, or criminal offence intending to facilitate or support such crime, or to support an individual or group of individuals planning such criminal offence.

AML / COMPLIANCE OFFICER

Win Vision has appointed a dedicated Compliance Officer to oversight the Compliance function who will be reporting to the Board of Directors of Win Vision. Any employee shall immediately notify the Compliance Officer if he/she suspects or has any reason to so suspect that any potentially suspicious activity has occurred or will occur if a transaction is completed. Employees are encouraged to seek the assistance of the Compliance Officer with any questions or concerns that may have with the respect to the Win Vision AML/KYC policy.

The Compliance Officer ensures that Win Vision functions in legal and ethical manner while meeting its business goals.

Compliance Officer shall ensure that:

Win Vision stays compliance with all applicable AML laws and Regulations and Win Vision owns AML/CFT and KYC policy.

Compliance Officer shall be responsible for:

  • Coordination of the enhanced due diligence procedures regarding clients of Win Vision;
  • Receiving and reviewing any reports of suspicious activity from employees, determining whether any suspicious activity as reported by an employee warrants reporting to senior management of the firm;

AML TRAINING PROGRAMME

All employees of Win Vision are expected to be fully aware of the Win Vision AML/KYC policy. Each employee is required to read and comply with this policy.

All employees should take at a time specified by the Compliance Officer training programs on AML/KYC policy and procedures.

All employees should be trained on how to recognize and deal with transactions which may be related to money laundering.

All employees should comply with all applicable AML laws and regulations.

KYC (Know Your Customer Procedures)

Win Vision know your customer procedures (hereinafter the „KYC”) and policies shall ensure that, prior to any financial interaction with client, all practical and reasonable measures are taken to confirm the Business identity. Company is reserving the right to cooperate with banks and/or any other financial institutions in order to successfully carry out the KYC.

Win Vision shall accept any finances from the client only after the KYC specified hereto has taken place and:

  • Win Vision has successfully confirmed the identity of the client that is acting exclusively in his name and on his own account.
  • In case that the client is acting on behalf of third parties, Win Vision has confirmed their identities according to these KYC.

Win Vision is reserving the right to apply enhanced measures on top of the standard KYC described hereto. The right to apply these enhanced measures is solely at discretion of Win Vision`s Compliance Officer.

Win Vision shall prepare individual checklist for the client and client shall provide Win Vision Compliance Officer with the most up to date documents demanded by this checklist. Win Vision is entitled to retain the copies of the provided documents in order to successfully carry out the KYC for client.

KYC PROCEDURE FOR NATURAL PERSONS

For the identification and due diligence purposes, client that is a nature person shall at minimum provide Win Vision with the following information:

  • Full name,
  • Date of birth,
  • Residential status, Nationality, Country of Residence,
  • Passport/ID scan,
  • Existing address for correspondence and Permanent address,
  • Mobile number,
  • Email address,
  • VAT number,
  • Utility bill (not older than 3 months)
  • Selfie with passport

KYC PROCEDURES FOR LEGAL ENTITIES

For the identification and due diligence purposes, client that is a legal entity shall at minimum provide Win Vision with the following information:

  • Full name of the company,
  • Company registration/incorporation number,
  • Date and country of incorporation,
  • Registered address and address for correspondence in case its different,
  • Type of business,
  • Name of parent company,
  • Email, website and contact numbers,
  • NTN number and sales tax number,
  • Details of contact person and authorized person,
  • Ownership structure chart (up to the UBO – natural person)
  • Register of Members
  • Register of Directors
  • Certificate of License being held

CLIENT SCREENING

In terms of these KYC, it is forbidden to provide services to the clients that have been previously rejected based on the past result of KYC procedure. Please also be noted, that Win Vision uses external 3rd parties’ programmes (World – Check) to screen its clients.

APPROVAL

Clients shall only be accepted only after the authorization by Compliance officer upon completing the KYC.

DENIAL

Client shall be denied only if:

  • Client did not provide documentation necessary for successfully carrying out the KYC or the results of the KYC is unsatisfactory.
  • Compliance Officer decides to do so.

POLICY REVIEW PERIOD

This Policy will be reviewed on as and when required, but not later than two years.