AML/KYC Policy

The AML/KYC Policy of Venlynx Sp. z.o.o. is designed to mitigate risks associated with money laundering and other illegal activities. This document highlights key aspects of our internal policy. For full details, contact customer service. Venlynx is required by law to establish procedures to prevent money laundering, terrorist financing, and related crimes.

The company assigns an Anti-Money Laundering Officer (AMLO) and ensures that staff members are fully aware of their duty to report any suspicious activities to the AMLO. It is essential that top managers have clearly defined roles and receive regular updates on money laundering risks. The company consistently maintains and updates its anti-money laundering policies, procedures, and controls. Any suspicions of money laundering are promptly reported to the relevant authorities.

Additionally, policies are implemented to integrate money laundering concerns into the company’s daily operations. Relevant staff members receive comprehensive training on their responsibilities in combating money laundering, and the company ensures prompt responses to any correspondence from the appropriate authorities.

1. FUNDAMENTAL PROCEDURES

Before executing any transaction for a new customer, the company must establish and implement several procedures. These include verifying the customer's identity, maintaining records, monitoring for unusual or suspicious transactions, and managing and reporting them internally as needed. The company also provides appropriate training to relevant staff, ensures they understand their roles and the organization's policies, and directs any external requests related to AML directly to the Anti-Money Laundering Officer (AMLO).

2. CUSTOMER IDENTITY VERIFICATION (KYC)

The company must ensure that all supporting documents received for verifying a new customer’s identity are credible and confirm that the customer is a legitimate individual or organization. While the company may seek external assistance during the onboarding process, it remains legally responsible for ensuring that the verification adheres to all applicable regulations. Additionally, the company will strictly follow its privacy policy and comply with legislation supporting the General Data Protection Regulation (GDPR) regarding the collection, storage, sharing, and protection of customer information.

3. ONGOING TRANSACTION OVERSIGHT

To effectively manage the risks of money laundering and terrorist financing, continuous monitoring of customer accounts and transactions is essential. The AMLO is responsible for establishing and enhancing the company’s monitoring procedures. Our transaction oversight emphasizes precision and promptness to ensure the security and reliability of our clients' payment operations.

4. RISK ANALYSIS

The company employs a risk-based strategy to focus on areas with higher risks of money laundering and terrorist financing, using appropriate protocols and guidelines. The AMLO is tasked with monitoring and assessing the effectiveness of these policies and processes.

The key components of the company’s risk-based strategy include:

• Allowing the board to modify rules, practices, and controls to meet the specific needs of the business.
• Enabling the board to differentiate between clients based on their individual business risks.
• Recognizing that various clients, countries, services, and financial instruments present different risks of money laundering or terrorist financing.
• Prioritizing actions based on the risk of money laundering and terrorist financing associated with the company’s services.
• Allows managing risks related to money laundering and terrorist financing.

5. SANCTION AND REGULATIONS

Venlynx Sp. z.o.o. adheres strictly to international regulations by prohibiting business with individuals, organizations, or countries subject to sanctions imposed by bodies such as the European Union and the United Nations. These sanctions aim to restrict financial and commercial dealings with entities involved in illicit activities or threats to global security.

To ensure compliance, Venlynx employs robust systems to check transactions, counterparties, and clients against relevant sanction lists. If any entity is found in violation, the company will promptly halt the transaction and inform the appropriate regulatory authorities. Adherence to these sanctions is a top priority, and all employees are trained to follow these policies.

Venlynx is committed to supporting international efforts to prevent illegal activities and maintain the financial system's integrity by enforcing sanctions regulations.

6. RESTRICTED REGIONS

Venlynx Sp. z.o.o. strictly adheres to all relevant laws and international regulations regarding money laundering risks and service provision. To comply, the company ensures it does not offer services to individuals in countries where money laundering risks are high or where business activities are prohibited or illegal.

These countries are selected based on assessments by global anti-money laundering organizations and evaluations of regions where our services could be misused. The company's detailed Anti-Money Laundering Policy, available upon request, lists these restricted jurisdictions. This list is subject to change based on decisions by company authorities, including the Anti-Money Laundering Officer (AMLO). Updated restrictions will take effect with policy revisions.

By restricting services to these high-risk jurisdictions, the company aims to minimize money laundering risks and ensure compliance with all relevant laws and regulations.

7. CONTACT US

If you have any questions or concerns about our Anti-Money Laundering and Know Your Customer Policy, or if you need further information or assistance, please contact our dedicated compliance team at - [email protected].

Moreover, we urge you to promptly report any suspicious transactions or activities involving our services to our compliance department. Your vigilance is crucial in maintaining the integrity of our operations and supporting our efforts to prevent money laundering.

We encourage you to reach out if you require additional information or have any issues related to the policy. We are committed to upholding the highest standards of anti-money laundering and compliance practices.

8. AMLO & COMPLIANCE

The ultimate authority for ensuring compliance with Anti-Money Laundering (AML) regulations lies with the Anti-Money Laundering Officer (AMLO). For clarity, in this document, "Anti-Money Laundering Officer" and "AMLO" denote the same individual. This person is vested with comprehensive authority and has access to all necessary information to effectively fulfill their role.

The AMLO is responsible for overseeing the implementation of AML policies and ensuring that all regulatory requirements are met. They have the capability to access relevant data, review transactions, and evaluate risks associated with money laundering.

This position is crucial for maintaining the integrity of the company's anti-money laundering framework, making certain that all measures are properly executed and adapted as needed to address emerging risks and regulatory changes.
 

To reach our compliance department, please contact us via email at: [email protected].