This policy on preventing and combating money laundering and knowing the client aims to inform Chidori Technologies SRL and ensuring the procedures for preventing and combating money laundering, respectively knowledge of the client, in accordance with the provisions of Law 129/2019 for the prevention and combating of money and financing to the law 129/2019 ”) and of the other applicable national and international regulations.
The terms and expressions written in the case in this policy on preventing and combating money laundering and knowing the clientele will have the meaning assigned under the conditions of use published on the company's website.
The information presented below refers mainly to:
Money laundering - represents the crime provided by article 49 of Law 129/2019: disguise under an appearance of legality of illegally obtained profits. Is done in three stages:
Financing of terrorism - represents the crime provided by article 36 of Law 535/2004 on the prevention and combating of terrorism: collection or provision, directly or indirectly, funds, bids or illicit, with the intention of being used or knowing that they are to be used, in part, for the commission of terrorism or to support an entity.
Reporting entity - represents the legal person who has the obligation 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 SRL has the capacity of rapporteur.
Real beneficiary - any natural person who eventually holds or controls the client and/or natural person on behalf or in the interest of which/to whom a transaction, an operation or an activity is carried out.
Knowing the clientele - measures to verify the customer's identity, the goals for which they trade, the identity of the real beneficiaries of the transactions carried out by the client and of any other information necessary for reporting suspicious transactions or for reporting the transactions that exceed the amount of 10,000 euros (or the equivalent in lei).
Customer/ clientele - any natural, legal or entity without legal personality with which the reporting entities carry out business relations or with which other operations of permanent or occasionally carry out. The client of an entity is considered to be any person with whom, in carrying out his activities, the reporting entity has negotiated a transaction, even if the respective transaction has not been completed, as well as any person who benefits or has benefited, in the past, the services of a reporting entity.
Suspect transaction - a transaction in connection with which there is a reasonable suspicion that it has as object goods from committing an offense/ respectively that the trading or its representative is not who is claimed to be; In any other situations or regarding elements that are likely to raise suspicions regarding the character, economic purpose or motivation of the transaction, such as the existence of anomalies to the client's profile, as well as when there are indications that the data held on the client or the real beneficiary are not real or topical, and the client refuses to update or offer them.
Persons exposed publicly - natural persons who exercise or have exercised important public functions, being included in the list of Article 3 of Law 129/2019.
ONPCSB is the unit of financial information of Romania (son) and is directly subordinated to the Government of Romania. The main objective of the Office is to prevent and combat money laundering by in -depth analysis of information and reports provided by the reporting entities, respectively by notifying the authorities in the hypothesis of reasonable suspicions regarding the offense of money laundering or financing terrorism.
As a reporting entity, Chidori Technologies SRL has the obligation to provide the Office reports on suspicious transactions or transactions whose value is at least 10,000 euros (or equivalent in lei).
ONPCSB is entitled to request any kind of information from Chidori Technologies SR.L which could be relevant in the prevention and combating of terrorism, and this is obliged to make this information available, in accordance with the legal provisions.
The policy defines the elements and measures that will be considered by the company's staff in order to identify, quantify and reduce the risk of money laundering and to finance terrorism through the services offered by it.
The company has implemented adequate instruments and applications for monitoring the transactions carried out through its ATMs / Website. These allow the company to carry out checks on transactions and identify any suspicious business relationships. In this sense, certain alerts are used that are activated at the time of reporting suspicious activities in customer accounts. At the same time, the staff of the company ensures that the history of the transactions carried out through the ATMs/ Website is stored properly.
The existing monitoring computer system uses the appropriate parameters, defined on the basis of national and international standards, while respecting the instructions issued by ONPCSB.
Knowing the clientele is the main means by which the policies to prevent and combat money laundering and terrorist financing are achieved. Through the checks undertaken on the occasion of expressing the client's intention to trading through the ATMs/ Website, the potential attempts to perform suspicious transactions can be identified and, consequently, the criminal activity can be prevented.
In view of the provisions of the conditions of use of Chidori Technologies SRL, customers can only trade within the indicated limits. It is also forbidden to trading through ATMs/ webiste, by the company by the public exposed persons.
The company also performs the following types of activities in order to comply with the legislation on preventing and combating money laundering and terrorist financing:
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