This is a short version of our Anti-money laundering (hereinafter referred to as: “AML”) and Counter-terrorist financing Policy, which Tradesilvania (Tradesilvania OÜ and Tradesilvania SRL) applies to its service.
The "money laundering" expression refers to all procedures used to cover up the origin of criminal revenues, so that they appear to come from a legitimate source. TRADESILVANIA aims to detect, manage and reduce all risks associated with money laundering and terrorist financing. The company has implemented a strict policy on detecting, preventing or reducing risks associated with any suspicious activities carried out by customers.
Our company constantly monitors the level of exposure to the risk of money laundering and terrorist financing.
The AML/KYC policy covers the following issues:
- Verifying the customers' background.
- Responsible for compliance.
- Monitoring transactions.
- Risk assessment
TRADESILVANIA believes that if it knows its client and understands its procedures well, it will be better prepared to assess risks and identify suspicious activity. The bank correspondence relationship shall not be established with "shell banks" and financial institutions if there are any doubts about whether or not the financial institution has a correspondent banking relationship with the "shell bank".
TRADESILVANIA is committed to establish and maintain policies, controls, procedures to manage and reduce money laundering and terrorist financing risks. These policies will be revised periodically to ensure that they are up-to-date and will include:
- risk management by TRADESILVANIA to prevent the use of its business for money laundering and/or terrorist financing.
- requests for customer background checks, paying particular attention to customers at high risk, for example, Politically Exposed Persons (PEPs).
- internal checks
- the independent audit of policies, checks and procedures.
- keeping records
- monitoring policy compliance
internal policies, procedures and checks
All our employees must go through a criminal record check as part of the employment process.
After the user sends all these documents, the account must be validated by a Tradesilvania employee in charge of this process. The main rule is for the customer to be at least 18 years old and a EU citizen.
All new customers shall be verified in the following databases:
- The criminal database, available on the Romanian/Estonia Ministry of Home Affairs website
- The Romanian/Estonia Courts portal
- Political involvement
The fiat payment can only be made if the account owner is the same as the bank account owner. Any bank account added by a customer must be verified by a Tradesilvania employee before being used for transactions.
If a transaction is part of the following types of transactions, we shall report this to the FIU (The Financial Intelligence Unit):
- Suspicious transaction;
- Cash transaction – applies to all cash transactions in RON, for amounts greater than 10,000 EUROs, regardless of whether there is one transaction or several, with a potential connection between them;
- External transfers – apply to all external transfers for amounts greater than 10,000 EUROs.
We monitor all transactions and when one seems suspicious, we shall request additional information from our customers, such as proving the source of the digital currencies. All customer documents will be stored by our company for a period of 5 years.
Verifying the customers' background.
One of the international standards for preventing illegal activity is the customers’ background check. Checking the customers’ background means identifying the customer and verifying his/her real identity based on documents, data or information, both at the time of initiating a business relationship with him/her, as well as doing this on a regular basis.
The customers shall provide the following identification information:
- Full name
- Date of birth
- Country of residence/location
- Email address
- Mobile phone number
- ID card
- Bank account
TRADESILVANIA will appoint a compliance officer for AML who will be fully responsible for the Company’s AML policy and will report any significant violations of the policy and of the internal procedures against money laundering, as well as of the regulations, codes and standards of good practice.
Our customers are monitored both by having their identity checked and their transactional patterns analyzed. We will monitor your account activity for unusual volumes, patters or types of transactions.
The procedure implies:
- The daily check of users so that they don’t get “blacklisted”;
- the management of cases and documents;
TRADESILVANIA will redirect any suspicious transaction to the Financial Intelligence Unit whenever a suspicious activity is identified in the customers’ accounts.
TRADESILVANIA implements a policy against money laundering and terrorist financing. We are able to ensure that the measures to prevent or reduce money laundering or terrorist financing are equivalent to the identified risks. Risk assessment is a key element to efficiently implement the AML policies and processes.