Anti-Money Laundering Policy
Internal control rules and procedures for prevention of money laundering and terrorist financing.
DESTREAM SERVICES LTD
Registry code: HE 418613
Legal address: Gladstonos, 139A, 1st floor, 3032, Limassol, Cyprus
Legal Basis
These Rules are based on:
- •Directive (EU) 2018/843 of the European Parliament and of the Council on prevention of money laundering
- •Cyprus Money Laundering Prevention and Suppression Law 188 (I) 2017, as amended
- •Financial Action Task Force (FATF) Guidance for a Risk-Based Approach to Virtual Currencies (2019)
Scope and Application
Business Relationship: Any withdrawal transactions of any amount from the Destream platform.
KYC/AML Requirement: Customers are obligated to pass full KYC/AML procedure before withdrawal transactions.
Coverage: All employees whose duties include establishment and monitoring of business relationships.
Risk-Based Approach
Identifying, assessing, and mitigating ML/TF risks
Risk Categories
Low Risk
- • Listed companies with transparency requirements
- • EU/EEA governmental authorities
- • Regulated financial institutions
- • Review every 2 years after first withdrawal
Medium Risk
- • Standard due diligence measures apply
- • Regular transaction monitoring
- • Periodic review of business relationship
- • Updated documentation required
High Risk
- • Enhanced due diligence required
- • Review within 6 months of first withdrawal
- • Senior management approval needed
- • Enhanced transaction monitoring
Customer Due Diligence (CDD) Measures
Know Your Customer principles and verification
Required CDD Measures
- Identification of customer and verification based on reliable sources
- Identification and verification of customer's representative
- Identification of beneficial owner (25%+ ownership)
- Understanding of transactions and gathering information
- Gathering information on politically exposed persons (PEPs)
- Transaction monitoring and ongoing due diligence
No Anonymous Transactions
The Company shall not enter into transactions with anonymous or unidentified persons. Transactions are declined if sufficient information is not provided for identification, purpose, or if the activity involves higher money laundering or terrorist financing risk.
Enhanced Due Diligence (EDD)
When additional scrutiny is required
EDD Triggers
EDD Measures Include
- • Additional verification based on independent sources
- • Gathering information on purpose and nature of transactions
- • Identifying source and origin of funds
- • Requesting first deposit from regulated EU/EEA bank
- • Obtaining senior management approval
- • Completion of AML questionnaire on website
Politically Exposed Persons (PEPs)
High-profile individuals requiring enhanced monitoring
PEP Definition
Individuals entrusted with prominent public functions:
- • Heads of state, government, ministers
- • Members of parliaments or legislative bodies
- • Members of supreme/constitutional courts
- • Members of central bank boards
- • Ambassadors and high-ranking officers
- • Directors of state-owned enterprises
Extended Coverage
Family Members
Spouse, children and their spouses, parents of PEP
Close Associates
Joint beneficial ownership, close business relations, entities set up for PEP benefit
EDD Measures for PEPs
- • Senior management approval to establish/continue relationship
- • Establish origin of wealth and source of funds
- • Designation of custom transaction limits
- • Enhanced transaction monitoring
- • Continued monitoring for 12+ months after leaving office
Transaction Monitoring
Identifying unusual and suspicious activities
Transaction Screening (Real-Time)
- •PEPs involved in transactions
- •Persons on sanctions lists
- •Payments from/to high-risk countries
- •Third-party payments
Transaction Analysis (Pattern Detection)
- •Large international payments (amounts ending in 0000)
- •Sudden increase in account activity
- •Transactions in multiple currencies
- •Cryptocurrency transactions to suspicious addresses
- •Transactions without lawful business purpose
Suspicious Activity Reporting
Reporting obligations to Financial Intelligence Unit
Immediate Reporting Required
Report to Cyprus Financial Intelligence Unit within 2 working days when suspecting money laundering or terrorist financing.
Transaction must be postponed until report is submitted, unless delay causes considerable harm or impedes catching perpetrators.
Confidentiality Requirement
Prohibited: Informing the customer, their beneficial owner, representative, or third parties about submitted reports, plans to report, or FIU restrictions. Breach of confidentiality constitutes a violation of the policy.
Relief From Liability
The Company, its employees, and representatives are not liable for damage arising from failure to enter into transactions or delays when reporting suspicious activity in good faith to the FIU.
Compliance Officer
Responsibilities
- • Collection and analysis of unusual/suspicious transactions
- • Reporting to Financial Intelligence Unit
- • Periodic statements to Board of Directors
- • Training employees on AML/CFT requirements
- • Applying control mechanisms
Requirements
- • Directly accountable to Board of Directors
- • Independent from other business processes
- • Impeccable professional and business reputation
- • Access to all relevant customer information
- • Right to participate in management board meetings
Record Keeping & Internal Audit
Document Retention
Minimum 3 years retention for:
- • Chargeback and dispute records
- • Evidence submitted
- • Refund and settlement documentation
- • KYC/AML verification documents
Internal Audit
Annual audit requirements:
- • Compliance verification with regulations
- • Risk assessment and prioritization
- • Effectiveness of control measures
- • Recommendations for improvement