Financial institutions and closely related entities (such as e.g. cryptocurrency exchanges) experience often attempts of money laundering and terrorist financing. Money laundering is defined as the process where the identity of the proceeds of the crime are so disguised that it gives the appearance of legitimate income. Terrorist financing is defined as the process of providing support to individual or group terrorists. Without direct terrorist financing, such activities as fund-raising, use and possession and funding arrangements also falls under the definition of terrorist financing.
Atheleum (the Atheleum) pays thorough attention to any activities that may be considered as money laundering or terrorist financing. Atheleum AML policy is designed to prevent money laundering by complying with AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of being used to facilitate the financial crime. To minimize and mitigate the risk of money laundering and/or terrorist financing, Atheleum implemented effective internal measures and procedures:
Establishment of the identity
Before any customer can access and benefit of Atheleum services, identity of such customer has to be established.
For Atheleum to be able to establish the identity of its customer, Atheleum must obtain sufficient data/documents/information from a (perspective) customer and verify such data/documents/information against independent sources. Customers that in the opinion of Atheleum pose higher risk may be investigated more thoroughly which may result in requesting of additional information and taking longer term for verification of the identity of such customer. Atheleum retains a right to re-establish the identity of the customer in cases where Atheleum sees it fit and in relation to that, request additional data/documents/information or renew previously submitted.
Assessment of risk
To mitigate and minimize the risks, Atheleum has adopted a risk-based approach which enables to identify, assess, and understand the money laundering and terrorist financing risk to which Atheleum is exposed, and take the appropriate mitigation measures in accordance with the level of risk. Risk based approach also allows to pay most of the attention to the higher risk and allocate most of the resources for mitigation of such risks.
To get to know its customers, Atheleum performs ongoing and retrospective monitoring. Monitoring performed by Atheleum intends not only to get to know the customer, but also to notice unconformities taking into comparison information submitted to Atheleum by the customer or obtained by Atheleum during establishment of the identity and such customer’s actual activities using Atheleum services and to catch any attempts of fraudulent, illegal or unlawful activity.
Atheleum uses both manual and automated solutions to track its customers’ transactions. Atheleum may use other measures on case by case basis.
Each suspicious activity will be thoroughly investigated and, if necessary, reported to the respective authorities or other restrictive measures taken to ensure no money laundering or terrorist financing activity is performed. Atheleum is entitled to request additional information/data/documents in relation to any transaction and the customer must follow such request.
Reporting to the authorities
Following its AML Policy and the applicable legal acts, Atheleum, when necessary, will report to the respective authorities of the activities that may be considered as money laundering and terrorist financing. Atheleum will not disclose any information about such report to have been made and will not address any questions in relation to that.
Atheleum has the assigned Compliance officer who is responsible for implementation of Atheleum AML policy, including but not limited to, of the above listed activities.