MONEY LAUNDERING AND TERRORISM FINANCING PREVENTION POLICY
1. Proactive. As a company providing cross-border financial services, Tierrapay undertakes to keep its accounts protected from flows of illicit money. We rely on national and international practice in order to effectively identify, assess and analyse any money laundering and terrorist financing risks to which we may be exposed.
2. Customer due diligence. We use set criteria and internal procedures to check our client's profiles. Customer due diligence measures are applied before establishing a business relationship with the client and afterwards, especially when there is a reasonable suspicion of money laundering or terrorist financing. We identify and verify the identities of both the customer and the beneficial owner as well as obtain and assess information regarding their intentions and activity.
3. Risk-dependent customer due diligence. When a client is considered high-risk (e.g. politically exposed persons (PEPs) in senior positions, their relatives and close associates) we will conduct enhanced customer due diligence. Likewise, if a client is considered low-risk, we will conduct simplified customer due diligence.
5. Storing personal data. By using Tierrapay services you agree for us to store your personal data for the purpose of the prevention of money laundering and terrorist financing for 10 years from the date of termination of a transaction or a business relationship. This includes documents confirming monetary operation or transaction and data or other legally binding documents and data related to the execution of monetary operations or conclusions of transactions. You also agree for us to store business correspondence with you for 5 years from the date of termination of transactions or business relationships with you for the same purpose. These time limits may be additionally extended for up to 2 years upon a reasoned instruction of a competent authority.
6. Reporting. Depending on the facts of each case, for example, if we know or suspect that property of any value is, directly or indirectly, derived from a criminal act or from involvement in such an act, or if we know or suspect that such property is used to support one or several terrorists or a terrorist organisation, we may report to the Financial Crime Investigation Service (FCIS) under the Ministry of the Interior of the Czech Republic.
7. Client's obligation. If the client, where required, 1) fails to submit data confirming his or her identity, 2) if the client submits insufficient data or data that are incorrect, 3) if the client or his or her representative avoids submitting information required for establishing client's identity, 4) if the client conceals the identity of the beneficial owner or avoids submitting information required for establishing the identity of the beneficial owner or the submitted data are insufficient for that purpose, or 6) if we cannot ensure that all the legitimate requirements are fulfilled, we reserve the right not to establish or continue business relationships and carry out transactions. We may also, upon assessment of the threat posed by money laundering and/or terrorist financing, decide on the appropriateness of forwarding a report to the FCIS. If we terminate a business relationship with a client because of a money laundering and/or terrorist financing threat, we will not responsible for non-fulfilment of contractual obligations and for the damage caused by non-execution of the client's monetary operations or transactions.
8. By using Tierrapay services you therefore confirm that 1) you have read, understood and agree with our Money Laundering and Terrorism Financing Prevention Policy, 2) all the data you provide us with before the commencement of our business relationship and afterwards are and will be correct, and 3) you understand and agree with what data we use and how we store and process this data for the purpose of money laundering and terrorist financing prevention.