The present AML Policy regarding the prevention and combating of money laundering and customer due diligence aims to inform the clients of CHIDORI TECHNOLOGIES S.R.L. and to ensure the implementation of procedures for preventing and combating money laundering, as well as customer due diligence, in accordance with the provisions of Law 129/2019 on the prevention and combating of money laundering and terrorist financing, as well as for the amendment and completion of certain legislative acts (“Law 129/2019”) and other applicable national and international regulations.
The terms and expressions written in capital letters in this AML Policy regarding the prevention and combating of money laundering and customer due diligence shall have the meaning assigned to them in the Terms of Use published on the Company’s Website.
The information presented below mainly refers to:
Money Laundering – represents the offense provided for in Article 49 of Law 129/2019: disguising illegally obtained profits under a legal appearance. It is carried out in three stages:
Terrorist Financing – represents the offense provided for in Article 36 of Law 535/2004 on the prevention and combating of terrorism: collecting or making funds available, directly or indirectly, licit or illicit, with the intention of being used, or knowing that they are to be used, in whole or in part, for the commission of terrorist acts or to support a terrorist entity.
Reporting Entity – represents the legal entity obliged to take measures regarding the prevention and combating of money laundering, in accordance with the provisions of Law 129/2019. According to Article 5 para. (2) of Law 129/2019, CHIDORI TECHNOLOGIES S.R.L. is a reporting entity.
Beneficial Owner – any natural person who ultimately owns or controls the Client and/or the natural person on whose behalf or in whose interest a transaction, operation, or activity is carried out, directly or indirectly.
Customer Due Diligence – measures to verify the identity of the Client, the purposes for which they trade, the identity of the real beneficiaries of the transactions carried out by the Client, and any other information necessary to report suspicious transactions or transactions exceeding the amount of 10,000 Euros (or the equivalent in RON).
Client/Customer Base – any natural person, legal person, or entity without legal personality with whom reporting entities carry out business relationships or other permanent or occasional operations. A client of a reporting entity is considered to be any person with whom, during its activities, the reporting entity has negotiated a transaction, even if the transaction was not finalized, as well as any person who benefits or has benefited, in the past, from the services of a reporting entity.
Suspicious Transaction – a transaction in relation to which there is a reasonable suspicion that it involves goods derived from the commission of an offense/that the person trading or their representative is not who they claim to be; in any other situation or regarding elements likely to raise doubts about the nature, economic purpose, or motivation of the transaction, such as anomalies compared to the client’s profile, as well as when there are indications that the data held about the client or the beneficial owner are not real or up to date, and the Client refuses to update them or provides implausible explanations.
Politically Exposed Persons – natural persons who hold or have held important public functions, included in the list under Article 3 of Law 129/2019.
ONPCSB is Romania’s Financial Intelligence Unit (FIU) and is directly subordinated to the Romanian Government. The main objective of the Office is to prevent and combat money laundering by thoroughly analyzing information and reports provided by reporting entities, as well as by notifying the authorities in case of reasonable suspicions regarding the commission of money laundering or terrorist financing offenses.
As a reporting entity, CHIDORI TECHNOLOGIES S.R.L. is obliged to provide the Office with reports regarding suspicious transactions or transactions with a value of at least 10,000 Euros (or the equivalent in RON).
Chidori Technologies has published the AML Policy and complies with all applicable laws.
ONPCSB is entitled to request any kind of information from CHIDORI TECHNOLOGIES S.R.L. that could be relevant in preventing and combating terrorism, and the latter is obliged to make such information available to the Office in accordance with the legal provisions.
The AML Policy defines the elements and measures to be considered by the Company’s staff in order to identify, assess, and mitigate the risk of money laundering and terrorist financing through the services it provides.
The Company has implemented appropriate tools and applications for monitoring transactions carried out through its ATMs/Website. Supporting these is the published AML Policy. These allow the Company to conduct transaction checks and identify potentially suspicious business relationships. In this regard, certain alerts are used, which are triggered when suspicious activity is detected in Clients’ accounts. At the same time, the Company’s staff ensures that the history of transactions carried out via ATMs/Website is properly stored.
The existing monitoring IT system uses appropriate parameters, defined based on national and international standards, while also complying with the instructions issued by ONPCSB.
Customer Due Diligence is the main tool for implementing policies to prevent and combat money laundering and terrorist financing. Through the verifications carried out when the Client expresses the intention to trade via ATMs/Website, potential attempts to conduct suspicious transactions can be identified, and consequently, criminal activity can be effectively prevented.
Considering the Terms of Use of Chidori Technologies S.R.L., Clients may trade only within the indicated limits. In addition, trading through the Company’s ATMs/Website by politically exposed persons is prohibited.
Furthermore, the Company carries out the following activities to comply with legislation regarding the prevention and combating of money laundering and terrorist financing: