MARKETING DE APOYO ESTRATEGICO SL is committed to the highest standards of the Anti-Money Laundering (AML) compliance and Counter-Terrorism Financing (CTF). The aim of the Companies Anti Money Laundering and Terrorist Financing Policy is to actively prevent the risks of these matters. To help the government fight the funding of terrorism and money laundering activities, law requires all financial institutions to obtain, verify, and record information that identifies each person opening an account. We are under the obligation to report suspicious activities of clients relevant to money laundering.

Money laundering

The process of converting funds, received from illegal activities (such as fraud, corruption, terrorism, etc.), into other funds or investments that look legitimate to hide or distort the real source of funds. The process of money laundering can be divided into three sequential stages:

Placement

At this stage, funds are converted into financial instruments, such as checks, bank accounts, and money transfers, or can be used for purchasing high-value goods that can be resold. They can also be physically deposited into banks and non-bank institutions (e.g., currency exchangers). To avoid suspicion by the company, the launderer may as well make several deposits instead of depositing the whole sum at once, this form of placement is called smurfing.

Layering

Funds are transferred or moved to other accounts and other financial instruments. It is performed to disguise the origin and disrupt the indication of the entity that made the multiple financial transactions. Moving funds around and changing in their form makes it complicated to trace the money being laundered.

Integration

Funds get back into circulation as legitimate to purchase goods and services.

MARKETING DE APOYO ESTRATEGICO SL adheres to the principles of Anti-Money Laundering and actively prevents any actions that aim or facilitate the process of legalizing illegally gained funds. AML policy means preventing the use of the company’s services by criminals, with the aim of money laundering, terrorist financing or other criminal activity.

To prevent money laundering, MARKETING DE APOYO ESTRATEGICO SL neither accepts nor pays cash under any circumstances. The company reserves the right to suspend any client’s operation, which can be regarded as illegal or, may be related to money laundering in the opinion of the staff.

Company Procedures

Does MDAE offer training for using new technologies?

MARKETING DE APOYO ESTRATEGICO SL will make sure that it is dealing with a real person or legal entity. MARKETING DE APOYO ESTRATEGICO SL also performs all the required measures in accordance with applicable law and regulations, issued by monetary authorities. The AML policy is being fulfilled within MARKETING DE APOYO ESTRATEGICO SL FX by the following means:

Know your customer policy and due diligence

Monitoring client’s activity

Record keeping

Know your customer:

Because of the company’s commitment to the AML and KYC policies, each client of the company has to finish a verification procedure. Before MARKETING DE APOYO ESTRATEGICO SL starts any cooperation with the client, the company ensures that satisfactory evidence is produced or such other measures that will produce satisfactory evidence of the identity of any customer or counterparty are taken. The company as well applies heightened scrutiny to clients, who are residents of other countries, identified by credible sources as countries, having inadequate AML standards or that may represent a high risk for crime and corruption and to beneficial owners who resides in and whose funds are sourced from named countries

Individual clients:

During the process of registration, each client provides personal information, specifically: full name; date of birth; country of origin; and complete residential address. The following documents are required in order to verify the personal information: A client sends the following documents (in case the documents are written in non-Latin characters: to avoid any delays in the verification process, it is necessary to provide a notarized translation of the document in English) because of the requirements of KYC and to confirm the indicated information:

• Current valid passport (showing the first page of the local or international passport, where the photo and the signature are clearly visible)

• Driving licence which bears a photograph

• National identity card (showing both front and back pages)

• Documents proving current permanent address (such as utility bills, bank statements, etc.) containing the client’s full name and place of residence. These documents should not be older than 3 months from the date of filing.

• In case the applicant company is listed on a recognised or approved stock exchange or when there is independent evidence to show that the applicant is a wholly owned subsidiary or a subsidiary under the control of such a company, no further steps to verify identity will normally be required. In case the company is unquoted and none of the principal directors or shareholders already has an account with COMPANYNAME, the following documentations must be provided:

• Certificate of Incorporation or any national equivalent

• Memorandum and Articles of Association and statutory statement or any national equivalent

• Certificate of good standing or other proof of registered address of the company

• Resolution of the board of directors to open an account and confer authority on those who will operate it

• Copies of powers of attorney or other authorities given by the directors in relation to the company

• Proof of identity of directors in case he/she will deal with MARKETING DE APOYO ESTRATEGICO SL on behalf of the Customer (according to the Individual identity verification rules described above)

• Proof of identity of the beneficial owner(s) and/or the person(s) on whose instructions the signatories on the account are empowered to act (according to the Individual identity verification rules described above)

Monitoring of client activity:

In addition to gathering information from the clients, MARKETING DE APOYO ESTRATEGICO SL continues to monitor the activity of every client to identify and prevent any suspicious transactions. A suspicious transaction is known as a transaction that is inconsistent with the client’s legitimate business or the usual client’s transaction history known from client activity monitoring. MARKETING DE APOYO ESTRATEGICO SL has implemented the system of monitoring the named transactions (both automatic and, if needed, manual) to prevent using the company’s services by criminals.

Record keeping:

Records must be kept of all transaction data and data obtained for the purpose of identification, as well as of all documents related to money laundering topics (e.g. files on suspicious activity reports, documentation of AML account monitoring, etc.). Those records are kept for a minimum of 7 years after the account is closed.

Measures taken:

In cases of an attempt to execute transactions which MARKETING DE APOYO ESTRATEGICO SL suspects that are related to money laundering or other criminal activity, it will proceed in accordance with the applicable law and report suspicious activity to regulating authority.

MARKETING DE APOYO ESTRATEGICO SL reserves the right to suspend any client’s operation, which can be regarded as illegal or may be related to money laundering in the opinion of the staff. MARKETING DE APOYO ESTRATEGICO SL has complete discretion to temporarily block the suspicious client account or terminate an existing client relationship.

Summary Of Anti-Money Laundering And Know Your Customer Policy (AML&KYC)