Tradesilvania SRL is actively involved in the efforts of preventing and combating money laundering and terrorism financing, both in terms of its capacity as a reporting entity according with the law requirements and in terms of financial service provider.

The active involvement in this approach aims, in addition to complying with the legal framework, and the safe administration of the customer base, the company's mission being to provide customers with access to its services in maximum security, both individually and collectively.

In order to comply with the applicable laws of preventing and combating money laundering and terrorism financing, Tradesilvania SRL has developed and implemented internal risk based compliance procedures.

This is a short version of our internal procedures for preventing and combating money laundering and terrorism financing (hereinafter referred to as „AML”), applied by Tradesilvania SRL (hereinafter referred to as „Tradesilvania”).

The internal procedures of preventing and combating  money laundering, terrorism financing and implementation of international sanctions, applied by Tradesilvania consist in:

• Know Your Customer (KYC) rules and measures regarding clients acceptance;
• Internal control procedures, applicable measures for risk assessment and management, compliance and communication management;
• Permanent monitoring of the operations performed by clients;
• Measures and procedures for protection of the employees involved in the implementation of such policies against any hostile or discriminatory threats or actions;
• Procedures for employees or persons in a similar position for reporting infringement of internal regulations through a specific, independent and anonymous channel with the observance of laws on personal data protection;
• Reporting and keeping records of all documents;
• Periodical training and assessment of employees.

Our services are available only for the residents of the European Economic Area.

Legal framework

The legal framework applicable to the KYC measures is as follows:

• Law no. 129/2019 for the prevention and combating money laundering and terrorism financing, as well as for amending and completing some legal acts;
• Order no. 37 on the approval of the enforcement Rules of the provisions of Law no. 129/2019 on prevention and combating money laundering and terrorism financing, as well as for amending and supplementing certain regulations,for the reporting entities supervised and controlled by the National Office for Preventing and Combating Money Laundering;
• Governmental Decision no. 603/2011 for the approval of the Norms regarding supervision by the National Office for Prevention and Control of Money Laundering of the method of application the international sanctions.

Useful links:

• the National Office for Preventing and Combating Money Laundering (O.N.P.C.S.B.);
• Financial Action Task Force (GAFI/F.A.T.F.);
• MONEYVAL Committee.

„Money laundering” concept

The term "money laundering" refers to all processes by which the source of illegally gained money is hidden to look like they originate from a legitimate source. TRADESILVANIA aims to detect, prevent and mitigate the risks associated with money laundering and terrorism financing. Therefore, Tradesilvania has implemented a strict policy intended to detect, prevent or mitigate the risks of any suspicious activity performed by its clients.

Internal policies, procedures and controls

TRADESILVANIA has implemented policies and procedures according to the standards required by national and European legislation, in order to identify and know its clients well. The Company is ready at any moment to assess risks and identify suspicious activities. The Company shall not have any business relationship with "shell banks" and financial institutions if there are any doubts that such financial institutions have entered into a banking correspondence relationship with "shell banks".

TRADESILVANIA is committed to establish and maintain policies, controls, management procedures for administration and mitigation of money laundering and terrorism financing risks. The internal policies implemented by Tradesilvania are periodically reviewed in order to keep these policies up to date.

Employees:

Tradesilvania requires its compliance employees to have high standards of professional competences and a good reputation. All Tradesilvania’s employees are subject to a verification process as a part of hiring procedure. Each person working in Tradesilvania is responsible for the implementation and compliance of the internal procedures for preventing and combating money laundering and terrorism financing.

Compliance Officer

TRADESILVANIA has appointed a compliance officer, who is fully responsible for drawing up and implementing in the Company, the procedures for preventing and combating money laundering and who will report any infringements of the laws on money laundering and terrorism financing as well as of the regulations, codes and standards of good practice.

All Tradesilvania’ employees are constantly trained in order to be sure that they are fully aware of their responsibilities in order to  prevent money laundering and terrorism financing.

Clients/transactions

In order to use Tradesilvania’ services, the potential customer must register in the Tradesilvania App by providing all data requested by the platform and acceptingthe terms and conditions of the Agreement and the Privacy Policy. After registration, in order to carry out the transaction, the potential client will get through the identity verification process, by uploading the identity document (identity card or passport, as the case may be), in compliance with the information requested during the enrolment process.

Tradesilvania does not open or operate anonymous or fictitious accounts for which the identity of the client is unknown, properly declared and verified.

Transactions monitoring

The internal procedures implemented by Tradesilvania include among others, a careful monitoring of the transactions made by clients using the trading platform.

Reporting suspicious activity

As a result of transaction monitoring, if a suspicious activity is found, this will be analysed and treated according to the law.

Tradesilvania has the right to request anytime to its clients the source of funds regardless of the traded amount.

All employees have the obligation to report any internal infringements of the legal provisions related to money laundering and terrorism financing, reporting nominally or anonymously any behaviour that violates the applicable laws in this field. Tradesilvania has established different anonymous communication channels for reporting the law violations, including the electronic form that can be accessed here.

Updating customer data

All Clients will update his/her data if any modification occurs to the information/documents provided during the enrolment process (i.e. change of the ID document, permanent address, telephone no., email, etc.).

Furthermore, according to its internal procedures and regulations in force, from time to time or whenever necessary Tradesilvania updates the data of its clients depending on the nature of each client, based on a specific internal analysis. Each client will be notified about the data updating process.

Archiving

All client documents will be kept by our Company for 5 years. In addition, all reports and related documents, including the reports received from employees or third parties via the reporting form will be kept for at least 5 years. If required by the competent authorities, the duration may be extended by no more than 5 years.

Risks assessment

TRADESILVANIA has implemented a policy based on preventing and combating money laundering and terrorism financing. We are able to ensurethat measures of preventing or mitigating money laundering and terrorism financing are proportionate  to the identified risks. Risk assessment is a key element for an efficient implementation of AML policies and processes. According to its internal rules and regulations, Tradesilvania has the right to refuse activating an account.