PTM Agreement
中国大陆/中国香港
Global
Privacy
Anti-Money Laundering and Counter-Terrorist Financing Policy of Hong Kong PTM Limited
Updated:[October 19th,2025 Version Controlled]
1. INTRODUCTION
1.1. Overview
Money Laundering (ML) is considered as a potent threat to financial system of all countries. The magnitude of its’ damage extends to a larger dimension inthe formofloss ofsovereigntyandimage ofa country. This has been recognized globally and has culminated in concerted efforts to fight this activity by way of enactment of stringent laws, regulations, and measures.
Hong Kong PTM Limited, established in Hong Kong, is committed to combat money laundering and terrorist financing and ensure that products and services products enlisted at Hong Kong PTM Limited are not misused for the purpose of money laundering, terrorism financing and other fraud events. It is also prohibited to provide any product or service or proceed any transaction for the benefit of individual or entity included in the international sanctions lists. As such, the adherence with applicable laws and regulations in relation to prevention of money laundering and terrorist financing (hereinafter referred to as “AML”) is mandatory and fundamental to Hong Kong PTM Limited’s strategy and program.
Hong Kong PTM Limited has strict and transparent standards and continuously strengthens its processes to ensure compliance with applicable AML laws and regulations.
Hong Kong PTM Limited reserves the right to reject any Client, payment or business that is not consistent with the Hong Kong PTM Limited AML policy subject to the requirements of the applicable AML laws and regulations.
1.2. Business Scope
Hong Kong PTM Limited is an innovative company based in Hong Kong. It offers secure and payment services.
2. GOVERNANCE FOR AML
Governance structure assigns responsibilities for the effective implementation of Hong Kong PTM Limited’s AML policies and monitoring structure and overall accountability.
Board Responsibilities
The Board of Directors has supreme authority and responsibility to implement robust guidelines relating to AML-CFT in Hong Kong PTM Limited Following are the main responsibilities of the Board of Directors:
a. Approving, enforcing AML Policy in Hong Kong PTM Limited
b. Establishing and approving the organizational structure, roles, and responsibilities in AML-CFT of individual department/unit.
c. Supervise the risk management on AML-CFT.
d. Review the AML-CFT status of Hong Kong PTM Limited on regular basis and provide feedback if any to the management or Compliance Officer (“CO”); and
e. Any amendments/cancellation or revision in the Policy shall be at the discretion of the Board of Directors.
2.1. Anti-Money Laundering Compliance Committee (AMLCC, Board Level)
Responsibilities
a. Review and support AML Policy for the purpose of approval of Board of Directors.
b. Review the AML-CFT status of Hong Kong PTM Limited on regular basis and forward to Board for further review.
c. Periodically review and update AML Policy; and
d. Monitoring AML-CFT related activities for the implementation of AML Policy.
2.2. Senior Management Responsibilities
Chief Executive Officer
Chief Executive Officer is a head of the management of Hong Kong PTM Limited who ensures that Hong Kong PTM Limited has implemented AML Policy and Procedures effectively. Following are the main functions of the Chief Executive Officer:
a. Ensuring that policies and procedures for AML-CFT Program are in line with the changes and developments in products, services, and information technology of Hong Kong PTM Limited as well as in line with development in modus for money laundering or terrorist financing.
b. Approving and enforcing AML/CDD Procedures of Hong Kong PTM Limited.
c. Ensuring that the implementation of AML-CFT Program is based on established policies and procedures.
d. Ensuring that all employees, particularly employees of related work units and new employees have participated in ongoing training related to AML-CFT Program.
e. Supervise the AML-CFT Unit work in implementing AML Policy and Procedure.
f. Based on the recommendation of CO for any action to respective staff for not complying AML Policy and Procedure, Chief Executive Officer shall take initiative for further action to such staff.
g. Ensuring that sufficient resources, suitable workplace, required access to information, document and staff have been managed to do compliance function effectively and efficiently; and
h. Other discretionary authorities shall be exercised as delegated in the Policy or by the Board from time to time.
-Compliance Officer (CO)
The CO shall be of a Senior Management grade of Hong Kong PTM Limited and who shall be the focal point for implementation of the AML Policy, Procedures and regulatory requirements relating to AML CFT. Hong Kong PTM Limited may appoint Assistant Compliance Officer (ACO), who shall assist in implementation of entire responsibilities of CO.Rights of the CO:
Rights of the CO:
a. Direct access to any documents, transactions and document related to accounts.
b. Right to demand/acquire any information, details, account statements or documents from any staff of Hong Kong PTM Limited; and
c. Direct access to any documents, information required for implementation of the AML-CFT Act, Regulations and Rules, and Internal Policy and Procedures.
Responsibilities of CO:
a. Effective policy, procedure and system shall be developed for the implementation of AML-CFT Program.
b. Suspicious monetary operation or transaction shall be reviewed / analyzed and sent to FIU.
c. Study the instructions issued by FIU and not later than within seven working days following the receipt of the instructions, report to the Financial Crime Investigation Service about the measures taken.
d. CO shall consult with another department or get specialist feedback, if needed.
e. CO shall prepare the report on the AML-CFT status of Hong Kong PTM Limited.
f. CO shall instruct to Hong Kong PTM Limited / all departments for complying the AML Policy, Procedure, and related laws and regulations.
g. CO shall make recommendation to take actions to those staffs who have not provided required information, document, and account details and/or who do not cooperate for the implementation of the AML Policy/Procedure to CEO and HR.
h. CO shall share the knowledge about the AML-CFT, its impact to Hong Kong PTM Limited and other details to the Shareholders, Board Members, Top Level Management and Staffs. External resource person may also be used, if needed.
i. CO shall facilitate to provide regular training about the AML-CFT to the staff for enhancement of AML- CFT knowledge and effective implementation in Hong Kong PTM Limited; and
j. As prescribed by Regulator.
Compliance Analyst
The compliance specialists from operation department of Hong Kong PTM Limited shall act as Compliance Analyst ("CA"). CA will have primary responsibility to implement of AML Policy and related Procedures. The major responsibilities of CA will be as follows:
For AML/CFT Compliance:
a. Ensure that Hong Kong PTM Limited’s AML Policy is available at Hong Kong PTM Limited and understood by the staff.
b. Ensure Client Due Diligence (CDD) and Client Identification process is followed in the opening an account.
c. Ensure that Enhanced Client Due Diligence is followed for high-risk Clients.
d. Identify and report any suspicious or unusual monetary operations and transactions performed by the Clients to CO/ACO
For other Compliance matters:
a. Policies, Procedures, and instruction of Hong Kong PTM Limited are always adhered to.
b. Ensure that staff in operation department are adequately trained about Hong Kong PTM Limited policies, procedures, and instructions.
c. All reports to CO/ACO are accurately prepared and sent in timely manner.
2.3. InformationTechnology Department (IT)
IT Department is responsible for providing necessary data and support to AML and CFT Unit, Receiving and dealing with AML systems optimization Suggestions from compliance department and operation department.
2.4. Audits
Hong Kong PTM Limited will obtain audit resources from internal or external sources:
- External Audits
Hong Kong PTM Limited contract an independent firm or qualified individual(s) to conduct AML compliance audit, audit will be conducted in a period ranging from 12 to 18 months.
The independent auditor, in his/her oversight capacity, will review the AML Compliance Policy/Procedure to ensure that it is being administered.
• Develop audit procedures and an audit plan that is risk focused.
• Evaluate the overall integrity and effectiveness of the AML policies, procedures, and systems.
• Perform transaction testing to evaluate the adequacy of the AML processing, determine the effectiveness of its policies, procedures, and systems, and evaluate monitoring of suspicious or unusual monetary operations and transactions performed by the Client. The audit scope should test transactions throughout all areas of account opening/transaction monitoring with emphasis on high-risk Clients, products, and services. In addition, conduct transaction testing to verify the record-keeping and reporting requirements.
• Evaluate employees'knowledge of regulations and procedures.Evaluate the comprehensiveness and effectiveness of the risk management program and review the risk assessment for the impact factors, such as products, services, Clients, and geographic locations which considered in Risk Rating Matrix (Appendix).
• Ensure timely reporting of appropriate issues to AMLCC.
• Ensure appropriate and timely follow-up on management's responses to deficiencies noted in audit reports and regulator examinations.
• Impress upon Hong Kong PTM Limited management the high priority that must be given to compliance.
• Identify any deficiencies and/or possible violations of law relating to AML.
• Prepare objective reports that clearly inform the Management and the Board of Directors of their findings; and
• Recommend corrective action to be taken in respect to deficiencies and violations of laws.
• Review of staff training for adequacy, accuracy, and completeness.
• Review the effectiveness of the suspicious activity monitoring systems (manual, automated or a combination) used for AML compliance. Related reports may include, but are not limited to:
• Assessment of the overall process for identifying and reporting suspicious activity, including a review of filed or prepared reports on suspicious or unusual monetary operations and transactions to determine their accuracy, timeliness, completeness, and effectiveness of the AML policy.
- Internal Examinations
After external audits has been conducted, the CO must receive the Audit Report or the Report of Examination, must review the report, answer any discrepancy, and make any corrective action. The AMLCC must meet to review and discuss the report. All discussions and actions taken by the Committee must be recorded in the minutes of the meeting. All reports of AML compliance examinations and audits must be presented to the Audit Committee of the Board for further presentation to the full Board of Directors, and AMLCC will monitor and follow up the progress of subsequent modifications and additions to current processes and practices.
CLIENT DUE DILIGENCE
The Company’s business is not involved with cash.Appropriate measures shall be taken to identify and verify the identity of the Clients and the beneficiary:
1) before establishing a business relationship.
2) before carrying out one-off or several related monetary transactions or concluding transactions equal to or exceeding EUR 10,000 or the equivalent in foreign currency, whether the transaction is carried out in one or more related transactions, unless the identity of Client and the beneficiary has already been established. If the final amount of a monetary transaction is not known at the time of the monetary transaction, the Company shall identify the Client immediately after determining that the number of monetary transactions is equal to or exceeds the monetary amounts.
3) when executing and accepting money transfers.
4) when there are doubts about the accuracy or authenticity of the previously received Client and beneficiary identification data.
5) in any other case where there is a suspicion that money laundering and / or terrorist financing activities are, have been or will be carried out.
3.1. Identification Methods
3.1.1. Clients must be identified during the KYC process. Detailed requirements on identification procedures are provided in Annex Two.
3.1.2. Clients may be identified by face-to-face contact or using non-face-to-face identification methods. This also applies to those cases where the Client, either natural or legal person, is represented by another person. When identifying Clients by face-to-face contact, the Client must provide an original personal identification document – for natural persons; or the registration and/or other corporate documents – for legal persons.
3.1.3. The non-face-to-face identification can be executed using electronic means, allowing direct view transmission, in one of the following ways: identity document or residence permit is captured using video-streaming and identity is confirmed using at least an advanced electronic signature, meeting the requirements referred to in Article 26 of Regulation (EU) No 910/2014.
Client's facial image and original identity document or residence permit are captured using video- streaming. The more detailed information and technical requirements for non-face-to-face identification methods are provided in Annex Three.
3.2. Information/documents Collection
- In relation to a client who is an Individual, below information are collected:
(a) the Client's name.
(b) the Client's residential address.
(c) the Client's date of birth.
(d) any other name that the Client is known by.
(e) the Client's country(is) of citizenship.
(f) the Client's country(is) of residence.
(g) the Client's occupation or business activities.
(h) account opening reason/ anticipated nature and level of transaction behavior.
(i) the source of wealth/origin of funds of the Client; (if necessary, proof of source of wealth/funds is required such as bank statements, proof of employment, income/salary statement, movable or immovable property such as real estate ownership, securities ownership, etc.)
(j) the beneficial ownership of the funds used by the Client.
(k) the beneficiaries of the transactions being facilitated by the reporting entity on behalf of the Client including the destination of funds.
The following Documentary are acceptable for an individual identification:
Identity verification:
• Valid Passport
• National ID Card
• Current photo-card driving license.
Address Verification:
• National ID Card
• Proof of recent utility bill (water, electricity, gas etc.)
• Bank Statement
• Other reliable source issued documents, such as government institutes issued documents containing individual address.
To identify the
- In relation to a client who is a legal person, below information are collected:
(a) the full name of the company.
(b) the full address of the company's registered office.
(c) the full address of the company's business operation.
(d) Business registration number.
(e) company shareholding structure.
(f) list of directors of the company.
(g) the nature of the business activities conducted by the company. (h) business source of funds.
(i) account opening reason/ anticipated nature and level of transaction behavior.
(j) the full name and address of each beneficial owner of the company (k) identification of directors/ authorized signatories/beneficial owners
The Documentary requirements for a legal person are as following:
• Certificate of incorporation and any change of name certificates.
• Registry List of Directors
• Certificate of Shareholders up to the UBO(s)
• Certificate of By-Laws (Memorandum and Articles of Association)
• Address of the registered office and name and address of registered agent, if applicable
• Address of principal place of business
• Sworn Statement as to non-existence of beneficial owners if applicable.
• Power of Attorney authorizing representatives if applicable
• Latest Audited Financial Statements if necessary
• Proof for business activity such as business agreements/contracts/invoice, bank statements, financial statement etc.
The above steps are essential prior to initiation of a business relationship with the potential Client and after the Client is engaged in the Business relationship, the following ML/TF prevention measure must be taken, which is considered as transaction Due Diligence:
• ongoing monitoring of the Business relationship with the Client and the Monetary operations and Transactions of the Client.
• Based on the CDD result, the Client can be turned away before a business relationship is formed, during the due diligence process or the stages following acceptance of a business relationship.
3.3. Additional Sources
3.3.1. In addition to the information and documentation provided by or on behalf of the Client and obtained from the Third parties (where relevant), the Company must check the below sources if the provided information is correct or to establish the missing information regarding the Client:
The following Documentary are acceptable for an individual identification: Identity verification:
(1) use of Dow Jones Risk and Compliance services.
(2) internet search engines (e.g.,www.policija.lt,www.google.com and other, especially in cases of PEPs).
3.3.2. The sources which the Company applies about the Clients may differ depending on the circumstances of each case. We must ensure that all results of such searches are available in our records and may be made available for the future needs or if required by the relevant authorities.
3.3.3. The requirement to double check the provided information by the Client may not be followed when the Client is the financial institution.
3.3.4. The Company will not open accounts for Clients that are unable to identify and verify identities. The Company refuses to open/keep anonymous accounts, fictitious named accounts.
3.4. Sanctions and Watchlists Screening
Risks related to lack of sanctions compliance, are potential threats or vulnerabilities that, if ignored or not properly handled, can lead to violations of the requirements subject to the EU, United Nations, or OFAC financial sanctions and negatively affect an organization’s reputation and achievement of business goals.
3.4.1 Sanctions Verification Process
The Company utilizes Dow Jones Risk Center as a tool to screen potential clients (new clients) both business and individual against worldwide Sanctions Lists, including but not limited to OFAC, EU and UN designated lists. Existing database is also screened against Dow Jones Lists as a Sanctions list is updated for potential positive Sanction matches. In addition, always transactions are screened against the Sanction Lists prior to being processed.
- Dow Jones Risk Center
Dow Jones Risk Center is a web-based tool for conducting full due diligence on potential Clients and connected parties, as well as ongoing monitoring and sanctions screening. The Company utilizes the Dow Jones Risk Center to perform searches for the following:
a. Watchlist (Sanctions, PEPs, etc.): a comprehensive database of sanctioned persons from OFAC, EU, UN, and worldwide governmental Sanctions lists, as well as PEPs.
b. State Owned Companies: worldwide SOC data that help identifying and monitoring corruption risk.
c. Adverse Media Entities: identification of companies that may have had negative media coverage.
The Company has considered those Clients, products, and services considering the following internal controls for screening and reporting of Sanction related issues:
a. Sanctions screening of Client at account opening.
b. Ongoing periodic Sanctions screening of Client if involved in a relationship.
c. Identification and review of suspect transactions; and
d. Reporting of suspect transactions.
New account Clients are checked by the Client Service Team and Compliance Analyst through the Dow Jones Risk Center, prior to account opening, and prior of processing transactions:
1) Accounts for individuals are checked for name of the account holder, all signers, those holding power of attorney and/or beneficial owners of the account if applicable.
2) Accounts for entities are checked for the name of the account holder, all signers, trustees, and/or those holding power of attorney if applicable. A check is also made of the names of beneficial owners of the entity, including persons-natural or otherwise-who own, control, or have the power to vote 25 percent or more of voting securities, or otherwise control the election of most of the directors.
3) In addition, the names of the entity’s suppliers and Clients are also verified through Dow Jones Risk Center, prior to engaging or entering a business relationship.
4) Wire Transfer transactions processed by the Company operating system are verified through the Dow Jones for the originator and beneficiary of wire transfers prior to transmitting an outgoing wire or accepting an incoming wire.
3.4.2. Ongoing Monitoring and Escalation Process
Ongoing monitoring shall be performed based on Clients’ risks. The Clients going through periodic review or trigger review will be scanned against Dow Jones for verification purpose.
If a transaction, transaction party, new account and/or established account match against any Sanction lists, it must be escalated to and reviewed by the CO. Whenever a search results in a possible match, the employee who conducted the search must bring the results to the CO to conduct enhanced due diligence to determine whether the match is valid. The CO will take further action as applicable to reject, block, report, apply for a license, or otherwise contact FIU and relevant regulatory body whenever further information or clarification is necessary.
If a transaction, transaction party, new account and/or established account is found to be a valid match against EU, UN, and/or OFAC lists, any funds for transactions requested or in process will be held, and the Client/Account will be temporarily deactivated and prevented from accessing any services.
The CO will have the responsibility of verifying the accuracy of the Sanction hit and determine if it’s positive. To avoid instances of mistaken identity, the following pieces of information concerning a person will be verified against that which is provided on the list: (a) date of birth; (b) known addresses; (c) current address; and (d) nationality (e) criminal record declaration.
If, after additional verification, it concludes that the match is indeed a positive match on Sanction lists, then the CCO will report to the Board of Director and decline the Client registration or permanently suspend all further activity, and any transaction request or in process will be frozen and reported.
3.4.3. File Documentation
All files must contain complete documentation evidencing due diligence measures taken to Sanctions verification.
The CO should also prepare Memorandum with respect to any consultations or other contact with regulatory authority. The Memorandum must clearly describe the events and conclusion as to whether a Sanction violation has occurred.
4. TRANSACTION MONITORING
4.1. Transaction Due Diligence
Client due diligence requires that we know of whose orders transactions are made and with whose funds. We will often ask you to justify why transactions are being made and demonstrate the economic basis of the payment. This may be done via telephone and/or by email. You should be prepared to provide us with invoices, purchase orders, delivery notes, contracts and any other documentary evidence that show the transactions that are being made have a verifiable economic basis.
We reserve the right to contact the other parties involved for confirmation of the legitimacy of the transaction we have requested further information on.
If Client is not able to provide the requested information and documentation to support a transaction, we may even be forced to reject the transaction.
4.2. General
The Company aims to have a full understanding of normal and reasonable account activity of its clients as well as of their economic profile and has the means of identifying transactions which fall outside the regular pattern of an account’s activity or to identify complex or unusual transactions or transactions without obvious economic purpose or clear legitimate reason. Without such knowledge, the Company shall not be able to discharge its legal obligation to identify and report suspicious transactions to the appropriate bodies. The constant monitoring of the Clients’ accounts and transactions is an imperative element in the effective controlling of the risk of Money Laundering and Terrorist Financing. The monitoring system relies both on automated monitoring and where appropriate, procedure monitoring by the staff of the compliance function.
4.3. Procedures
The procedures and intensity of monitoring accounts and examining transactions are based on the level of risk and, as a minimum, achieve the following:
(a) Identifying all high-risk Clients, as applicable; the Company shall have in place systems or measures and procedures that will enable the Company to produce detailed lists of high-risk Clients, to facilitate enhanced monitoring of accounts and transactions, as deemed necessary.
(b) Detecting of unusual or suspicious transactions that are inconsistent with the economic profile of the Client for the purposes of further investigation.
(c) The investigation of unusual or suspicious transactions from the employees who have been appointed for that purpose; the results of the investigations are recorded in a separate memo and kept in the file of the Client concerned.
(d) all necessary measures and actions must be taken, based on the investigation findings of point (c), including any internal reporting of suspicious transactions/activities to the MLCO.
(e) Ascertaining the source and origin of funds credited to accounts.
(f) Identifying transactions which, as of their nature, may be associated with money laundering or terrorist financing Transactions executed for the Client are compared and evaluated by the MLCO and staff of compliance function against:
• The anticipated account’s turnover.
• The usual turnover of the activities/operations of the Client.
• The data and information kept for the Client’s economic profile.
The Company will introduce and implement the use of appropriate and proportionate IT systems which will be capable of supplying the Board of Directors and the MLCO, on a timely basis, all the valid and necessary. information for the identification, analysis and effective monitoring of Client accounts and transactions based on the assessed risk for money laundering or terrorist financing purposes, in view of the nature, scale and complexity of the Company’s business.
4.4. Unusual/ Suspicious Transaction Management
4.4.1. Unusual/ Suspicious (need further inquiry) activities.
A transaction which appears unusual is not necessarily suspicious. Therefore, the unusual is, in the first instance, only a basis for further inquiry. This would then require judgement as to whether it constitutes suspicion. Below is the list of criteria of ML and TF which also serve as the examples of the ML/TF activities.
Suspicious transactions are determined by the Employees of the Company when applying the ML/TF prevention measures established under this Procedure and paying attention to the Transactions which according to the documentation and information obtained and the criteria listed below could be related to ML/TF.
The following are some examples of unusual/suspicious activities:
• Transactions with no discernible purpose or are unnecessarily complex.
• Use of foreign accounts of companies or group of companies with complicated ownership structure which is not justified based on the needs and economic profile of the Client.
• The transactions or the size of the transactions requested by the Client do not comply with his usual practice and business activity.
• Large volume of transactions credited into an account when the nature of the Client’s business activities would not appear to justify such activity.
• The Business Relationship involves only one transaction, or it has a short duration.
• There is no visible justification for a client using the services of a particular financial organization. For example, the Client is situated far away from the financial organization and in a place where he could be provided services by another financial organization.
• There are frequent transactions in the same financial instrument without obvious reason and in conditions that appear unusual (churning).
• Any transaction the nature, size or frequency appear to be unusual, e.g., cancellation of an order, particularly after the deposit of the consideration.
• Transactions which are not in line with the conditions prevailing in the market, in relation, particularly, with the size of the order and the frequency.
• Settlement of the transaction by a third person which is different than the Client which gave the order.
• Instructions of payment to a third person that does not seem to be related with the instructor.
• A Client is reluctant to provide complete information when establishes a Business Relationship about the nature and purpose of its business activities, anticipated account activity, prior relationships with financial organizations, names of its officers and directors, or information on its business location. The Client usually provides minimum or misleading information that is difficult or expensive for the financial organization to verify.
• A Client provides unusual or suspicious identification documents that cannot be readily verified.
• A Client’s home/business telephone is disconnected.
• A Client that makes frequent or large transactions and has no record of past or present employment experience.
• Difficulties or delays on the submission of the financial statements or other identification documents, of a client/legal person.
• A Client who has been introduced by a foreign financial organization, or by a third person whose countries or geographical areas of origin do not apply, or they apply inadequately FATF’s recommendations on Money Laundering and Terrorist Financing.
• Shared address for individuals, particularly when the address is also a business location and/or does not seem to correspond to the stated occupation (e.g., student, unemployed, self-employed, etc.).
• The stated occupation of the Client is not commensurate with the level or size of the executed transactions.
• Financial transactions from non-profit or charitable organizations for which there appears to be no logical economic purpose or in which there appears to be no link between the stated activity of the organization and the other parties in the transaction.
• Unexplained inconsistencies arising during the process of identifying and verifying the Client (e.g., previous, or current country of residence, country of issue of the passport, countries visited according to the passport, documents furnished to confirm name, address, and date of birth, etc.).
• Complex trust or nominee network.
Considering the activity of the Company and the nature of financial services provided by the Company, the Company’s Compliance Analysts should stay alert to the following red flags:
(1) the fields of activity specified in the registered identification document of the Client (legal persons) such as business registration, do not correspond to the usual Business relationship between the Company and the Client.
(2) the nature of the Monetary operations or Transactions conducted by the Client raises suspicion and when requested by the company the Client does not provide the reasonable explanations and information regarding the performed transaction.
(3) the Client makes such Monetary operations (acquisition of E-money and/or payments) which exceed the paying capacity of the Client known to the Company; the payment capacity of the Client is established based on the information obtained during the due diligence procedure as well as the results of the ongoing monitoring of the Client.
(4) the Client asks to pay the amount due to the Client to persons who are obviously unrelated to the usual field of activity of the Client; and when requested by the Company the Client cannot provide the reasonable explanations and information regarding such Monetary operations.
(5) the full amount of advance payment or other contribution (or a major part of the latter) is paid by persons that obviously have no relation to the usual activity of the Client; and when requested by the Company the Client cannot provide the reasonable explanations and information regarding such Monetary operations.
(6) the Client performs Monetary operations or concludes Transactions for which it is difficult or impossible to identify the Beneficial owner (where applicable) and when requested by the Company the Client cannot provide the reasonable explanations and information regarding such Monetary operations or Transactions as well as refuses to identify the Beneficial owner (where applicable).
(7) the Client conducts Monetary operations or concludes Transactions for which there is no clear economic grounds, or which do not correspond to the usual Business relationship with such Client; this criterion is considered fulfilled if requested by the Company the Client cannot provide or refuses to provide the reasonable explanations and information regarding such Monetary operations or Transaction.
(8) the Client consistently performs Monetary operations or concludes Transactions with legal persons or other organizations which are registered in the Target territories, when there are no clear economic grounds for this activity; and when requested by the Company the Client cannot provide the reasonable explanations and information regarding such Monetary operations.
(9) the Client consistently conducts Monetary operations or concludes Transactions with the legal or natural persons from the territories other than FATF countries as provided in the list available under the following link: http://www.fatf-gafi.org/countries/#high-risk;
(10) the transfers in small amounts from different payers to the Client or the transfers in small amounts by the Client to numerous unrelated payees which become extraordinarily frequent without obvious reasons and does not correspond to the usual Business relationship with the Client; this criterion is fulfilled if requested by the Company, the Client does not provide or refuses to provide the reasonable explanations and information regarding such Monetary operations.
Proper attention should be given to other circumstances which are not explicitly listed above but may raise suspicions on ML or TF. Also, special attention must be given to the complex or unusually large transactions and all unusual patterns of transactions which have no apparent economic or visible lawful purpose, and Business relationship or Monetary operations with the End Clients from the countries outside the EU and the third countries with the equivalent regime.
If any suspicious activity listed above or other types of suspicious activity are noticed, such activity should be immediately reported to the CO. If necessary, an investigation of the matter may include gathering additional information internally or from Third parties or other sources as well as suspending the Monetary operation or Transaction and filling a Suspicious Transaction Report with the FIU.
4.4.2. Transaction Monitoring Tool / System
- Monitoring Suspicious Activity on All Clients/Accounts
Monitoring process will involve a combination of manual and automated detection. To properly allocate the Company’s resources in the most efficient manner possible, the extent of the monitoring for each Client and account will be dependent on the risk rating assigned to such Client and/or account, with particular emphasis on high-risk Clients.
The Company should ensure that adequate staff is assigned to the identification, research, and reporting of suspicious activities. The Company will develop transaction monitoring rules to cause the Compliance staff attention of unusual activity. Upon identification of unusual activity, the matter should be escalated to the CO for further judgement.
- Process of Monitoring Transactions
• Both the originator and beneficiary of each Monetary operation or transaction are verified through the Dow Jones Risk Center application for Sanctions and other name lists checks. All potential positive matches must be further reviewed by Compliance team before the Monetary operation or transaction can be processed.
• Compliance Analysts monitor all transaction applications initiated by Clients in the system, identifying those Monetary operation or transactions with questionable purposes and/or transaction patterns, such as violation of established Client KYC profile, or does not correspond with the Client’s transaction history, or suspected phony documentation submitted as the proof of transaction purpose.
• Obtain information on the specific Monetary operation or transactions, such as originator, beneficiary, currency, amount, countries, and transaction purpose.
• Escalate the Monetary operation or transaction to the CO to see whether further investigation should be undertaken.
• Any such investigation would take place only under the direction of the CO, and might include gathering additional information from third-party sources, such as Internet, Dow Jones Risk and Compliance web-based application, Client Service’s inquires, Existent cases referred for investigation, etc.
• The CO will determine whether to file a SAR after such investigation and must report to the BOD about the decision.
4.5. In Case of Suspect
4.5.1. Internal Report. If it is identified, what is believed to be a suspicious transaction, it must immediately report to the CO. This report should be made in writing and before executing the client’s instructions to affect a transaction.
4.5.2. Tipping off. No member of staff or personnel may disclose to the Client concerned or to a third party, the fact that an investigation is being carried out, or that information has been transmitted to the FIU, since such disclosure might prejudice any investigation being carried out. Furthermore, at no stage may any member of staff or personnel, tip off or warn the Client specifically about the Company’s reporting. obligations or that it has filed a report as this would be tantamount to alerting a suspected criminal that we have uncovered his illegal activity. Furthermore, such tipping off to the Client is likely to prejudice the effectiveness of any investigation or actions regarding a suspicious Transaction.
4.5.3. If the Client is inadvertently alerted to ongoing investigations, we are to immediately seek guidance from the FIU as to how we should act.
4.5.4. External report. If the CO finds the Monetary operation or Transaction as Suspicious Monetary operation or Transaction, the CO must suspend the Monetary operation or Transaction, regardless of the amount of the Suspicious Monetary operation and Transaction, save for the cases where the Monetary operation of Transaction is already fully executed,and report it to the FIU within 3 (three) working hours.
4.5.5. The Company may be also instructed by the FIU to suspend the Monetary operation or Transaction which the FIU alleges to be a ML/TF mean. In the latter event the Company must suspend such Monetary operation or Transaction for up to 10 (ten) business days.
4.4.6. The FIU must verify the reported Monetary operation or Transaction within 10 (ten) business days as of the receipt of the respective report or as of the submission of the respective instructions to the Company.If within 10 business days as of the suspension of the Suspicious Monetary operation or Transaction the Company is not required to perform temporary restriction of ownership rights according to the procedure established by the Code of Criminal Procedure of the United States. the Monetary operation or Transaction must be resumed.
4.5.7. The FIU may request the Company to provide all necessary information which is needed for the FIU to carry out the verification of the Suspicious Monetary operation or Transaction. In the latter event the Company must provide the requested information within 1 (one) business day after the receipt of the respective request of the FIU.
4.5.8. The FIU must be urgently reported (no suspension is needed) by the Company, if the Company obtains the information that the Client intends or will attempt to perform a Suspicious monetary operation or Transaction.
4.5.9. The Company must ensure that any information requested by the FIU is provided to the FIU within 14 (fourteen) business days unless the shorter periods are established in this Procedure or by the law.
4.5.10. The Company, including its Employees acting in good faith, are not responsible to the Client for the non-fulfillment of any contractual obligations and for the damage caused due to the reporting and suspension of the Suspicious Monetary operations and Transactions as well as for the provision of the information upon the request of the FIU.
All reports to the FIU must be submitted in the FIU electronic system by filling the respective electronic form of report. If due to any reasons the submission of the report to the FIU via the FIU electronic system is not available, respective report must be submitted via the e-mail or fax without any delay.
The FIU may ask for the additional information in writing or via e-mail. In the latter event the requested information must be provided in writing or via e-mail or fax.
All correspondence with the FIU is to be retained, and that written records of all telephone conversations are made. Copies of all relative documentation are to be kept in file.The CO is to request guidance from the FIU on all relevant matters.
5. RISK ASSESSMENT
5.1. Client Risk Assessment
An important aspect of the due diligence process is the assessment of the risks involved and the acceptability of a prospective Client. Before agreeing to provide a service to a prospective Client, an assessment of the risks involved should be completed. This involves assessing the acceptability as a client and the risk associated with the services requested by the Client. This on-going evaluation is necessary to consider relevant issues before deciding as to whether the required E-money services should be provided.
When entering the Business relationship with the Client, the ML/TF risk is assessed based on the documentation and information obtained from a prospective Client Special attention must be given to the behavior of and the verbal communication with a prospective Client as well as the criteria of the High- Risk Clients and Low Risk Clients as listed in Sections 8 and 9 below. When assessing the ML/TF risk the aim is to establish and assess the following circumstances:
(1) type of the Client, i.e., whether a prospective Client meat the profile of the typical client of the Company; if not, the additional clarification and/or documentation must be requested from the Client seeking to establish if there is a high ML/TF risk; the special attention is given to the following circumstances which may increase the ML/TF risk:
a. if the Client is a PEP.
b. where the prospective Client is registered under the address which serves as a registration address for several companies.
c. where the same person acts as a managing director or a Beneficial owner for several companies (save the large corporate groups).
d. where the prospective Client is a non-profit institution (“NPI”).
e. other circumstances indicated in these Procedures.
(2)commercial relationships, i.e. assessing if the behavior of a prospective Client reveals that the aims and duration of the relationship expected by a prospective Client may considerably differ from what is inherent to the profile of the typical Client of the Company; if yes, the additional clarification and/or documentation must be requested from the Client seeking to establish if there is a high ML/TF risk; in addition it needs to be established if the Client acts as a principal or is represented by the third person (agent);
(3)product, i.e. assessing if the E-money services in which a prospective Client is interested correspond the nature of the business and the Transaction profile of such prospective Client; if not, the additional clarification and/or documentation must be requested from the Client seeking to establish if there is a high ML/TF risk; attention should be drawn where the Client or the potential Client is to transact in new or developing technologies which may give rise to a threat of ML/TF or the use of Monetary operations or Transactions that might favor anonymity;
(4)territory, i.e., assessing where the main place of interests of a prospective Client is situated,e.g. where the Client is living/incorporated or where the place of the main business activity of the Client is situated or where the main part of the Clients of the Client comes from; it is important to establish if such main place of interests of the Client is situated in the country other than FATF country or in the Target territory; in such event the Client has to be considered as a high risk client.
The Company has used risk matrix, which is a separate document considering seven risk categories, i.e., "Client Identification", "Client Profile", "Nature of Business", "Geographic Location of Market Area or Client Base", "Type of Product or Service", "Expected Transaction Activities", and "Source of Business Funds". Each category is divided into several risk factors, and the same risk weight is allocated to each risk factor.
The following circumstances shall indicate a high risk and accordingly trigger high risk due diligence level:
(1) a prospective Client starts to express his interest in the topics related to ML/TF.
(2) a prospective Client discloses that the funds to be accumulated through the E-money services provided by the Company are intended to be transferred to the third person from and/or to the territories other than the FATF counties.
(3) a prospective Client is reluctant to perform the actions necessary for identification and to provide information related to the Client and its financial activity.
(4) a prospective Client fails to provide documents or information requested by the Employee or non-face-to-face identification measures for the identification purposes, especially information/documentation evidencing the financial activity of the Client.
(5) the doubts regarding the correctness or authenticity of the documents or information provided by a prospective Client arises.
(6) a prospective Client is not able to answer the questions provided by the Employee or by non- face-to-face identification measures and related to the financial activity of the potential Client, the nature, and the aims of such activity.
(7) a prospective Client is unusually stressed and nervous during the verbal communication with the Employee, especially when asked the questions related to the financial activity of a prospective Client.
The Officer must use the Risk Matrix and assess the above circumstances to decide whether to refuse accepting the Business relationship with such potential Client or, if decided to further proceed with the due diligence procedure, the enhanced due diligence must be applied.
After the risk assessment is performed, the Client is assigned to one of three categories according to its risk profile:
(1) Medium Risk Clients who do not qualify as the High-Risk Clients or Low Risk Clients – the standard due diligence and ML/TF prevention measures apply.
(2) High Risk Clients who are defined in Section 6 below – the enhanced due diligence and ML/TF prevention measures apply.
(3) Low Risk Clients who are defined in Section 7 below– the simplified due diligence and ML/TF prevention measures may apply.
The profile of the Client is reviewed periodically (High Risk Clients are to be reviewed at least once a year) reflecting the changes in the Business relationship and behavior of the Client as well as based on the results of the ongoing monitoring of the Client. The Company may not apply periodical revision when the Client is a financial institution. Thus, the risk profile and, accordingly, the ML/TF prevention measures applied with respect of the Client may change from time to time.
We must ensure that all risk assessment documentation as well as the results of the risk assessment and all changes to the risk profile of the Client are available in our records (i.e., data basis) and may be made available for the future needs or if required by the relevant authorities.
5.2. Restrictions in opening of account
The Company deems that certain types of accounts generally pose extremely high money laundering risk.
Thus, the Company, as a matter of policy, will not solicit, open, or maintain the types of accounts listed below:
a. Accounts where the Company is unable to identify the Client and beneficiary.
b. Payable Thru Accounts.
c. Foreign accounts for individuals or entities from countries designated by FATF-GAFI as high-risk jurisdictions subject to a Call for Action.
d. Foreign accounts for individuals or entities that are currently sanctioned by OFAC, UN, EU, and other governmental sanctions.
e. Political Party campaign accounts.
f. Shell Banks
g. Engaging in business activities that are prohibited under this Policy (Annex Five)
h. Other prohibited type of Clients/Accounts based on the Risk Matrix results for assessing Client risks.
6. ENHANCED DUE DILIGENCE PROCEDURES
We are to apply enhanced due diligence procedures in the following instances:
6.1. High Risk Clients/Accounts
- The Company deems that certain types of clients/accounts generally are considered to pose a higher risk of ML/TF. Hence the requirements of applying enhanced due diligence measures and ongoing monitoring. For instance, electronic money institution, payment institution, PEPs etc.
• Financial institutions
If the Client is a financial institution such as an electronic money institution and/or payment institution covered by the Law on the Prevention of Money Laundering and Terrorist Financing of the United States, or a financial institution registered in another EEA Member State or in the third country which imposes equivalent requirements to those laid down in the laws of the United States, then:
(a) must apply to the authorized senior management of the Company for the approval to establish a Business relationship with such Client.
(b) the appropriate measures must be taken to evaluate the AML/CTF control system of the financial institution, including but not limited to:
i. regulatory license/authorization.
ii. latest AML program. iii. AML/CTF Questionnaire.
iv. Certificate of registration, business registration if any, memorandum, and articles of association.
v. Company registry document indicating the shareholding structure, directors and/or senior management.
vi. Proof of ownership structure, such as organization chart.
vii. Identification documents and address proof documents of all ultimate beneficial owners, and authorized signers designated to establish the relationship. viii. Latest annual report and/or audited financial statement.
(c) the enhanced ongoing monitoring of the Business relationship with such type of Client must apply to ensure that the Client keeps fulfilling its obligation of combating ML/TF.
Hong Kong PTM Limited is not prone to the risk of opening accounts to financial institutions. Requests for such accounts will not be accepted unless preliminarily investigated by the Chief Compliance Officer on a case-by-case basis and final approved by the Board of Directors. In such instances the Board of Directors, if the circumstances warrant, may grant the opening of the account, and must document the reasoning for the decision accordingly.
• High risk businesses
Some clients and businesses are more vulnerable to money laundering and/or other criminal risks, such as - Precious metals/ jewelry dealers
- Trust
- Private Funds
- Real Estate companies - Pawnbroker
- Bail Bonds agent/dealer
- Third Party Payment Processors
- Professional service providers (for example: Lawyers, Accountants, Notaries, Real Estate Agents, Investment brokers, and other third parties that act as financial liaisons for their clients)
- Privately owned ATMs
- Vending Machine Operators
The following controls must be fulfilled:
(a) must apply to the authorized senior management of the Company for the approval to establish a Business relationship with such Client.
(b) the appropriate measures must be taken to evaluate the AML/CTF control system of the financial institution, including but not limited to:
(c) the enhanced ongoing monitoring of the Business relationship with such type of Client must apply to ensure that the Client keeps fulfilling its obligation of combating ML/TF.
Hong Kong PTM Limited is not prone to the risk of opening accounts to high-risk businesses. Requests for such accounts will not be accepted unless preliminarily investigated by the Chief Compliance Officer on a case-by-case basis and final approved by the Board of Directors. In such instances the Board of Directors, if the circumstances warrant, may grant the opening of the account, and must document the reasoning for the decision accordingly.
After the risk assessment is performed, the Client is assigned to one of three categories according to its risk profile:
• Politically Exposed Persons
The identification and risk assessment process (Annex Two to these Procedures) or the ongoing monitoring may reveal the Client or the Beneficial owner (where applicable) to be a PEP as defined in Section 1 of these Procedure. If it is established that the Client or the beneficial owner is a PEP, then:
(a) this must be notified to the Officer who verifies the information and documentation obtained as well as the additional sources (if needed) and decides whether to refuse (terminate) the Business relationship with such Client or to apply to the authorized senior management of the Company for the approval to establish (continue) a Business relationship with such Client.
(b) the appropriate measures must be taken to establish the source of property and funds related to the Business relationship, Monetary operation, or Transaction.
(c) the enhanced ongoing monitoring of the Business relationship with the PEP must apply to ensure that the source of wealth and funds that are involved in the PEP’s personal/business Monetary operations and Transactions are legitimate.
Hong Kong PTM Limited does not open accounts to PEPs.
- Clients that may pose higher risks are also those who are assigned to this category after the risk assessment or due to the results of the ongoing monitoring, for example:
(a) those who do not correspond to the profile of the typical Client of the Company significantly and after carrying an additional investigation the Employee decided that the Client or its activity raises high ML/TF risk.
(b) those whose behavior during the due diligence procedure was suspicious and, therefore, reported to the Officer who after carrying an additional investigation decided to proceed further with the enhanced due diligence procedure.
(c) whose commercial relationship or behavior during the due diligence procedure were unusual and after carrying an additional investigation it is decided that the Client or its activity raises high ML/TF risk.
(d) the Client performs transfer operations on the request of persons not related to the main activity of the Client.
(e) the permanent place of residence of the Client – natural person (where applicable) is a territory other than FATF Members and/or FATF Associate Members.
(f) the Client – legal person or another organization is registered in a territory other than FATF Members and/or FATF Associate Members.
(g) the main place of the interests of the Client is situated in the country other than FATF Members and/or FATF Associate Members.
(h) the check in the additional sources reveals that the data of the Client, its representative (where applicable) or the Beneficial owner conform to the data of the persons associated with the ML/TF as specified in the respective lists of the United States, EU, FATF or the United Nations.
(i) the check in the additional sources reveals that the data of the Client, its representative or the Beneficial owner (where applicable) conform to the data of the persons under the financial sanctions in accordance with the Law on Implementation of Economic and other International Sanctions of the United States.
(j) the unusual behavior of the Client is established that does not correspond to the ordinary course of activities of the Client (e.g., increasing amounts of payments, especially to the payees or for the goods or services that do not correspond the declared activity of the Client).
(k) those who were assigned to the category of the High-Risk Client due to other reasons that raises high ML/TF risk of the Client.
6.2. Enhanced Due Diligence Measures
In all the above instances and apart from normal due diligence procedures, at least one of the following additional measures must be taken:
(a) the additional data, documents or information must be used to establish the Client’s identity.
(b) the supplementary measures must be undertaken to verify or certify the submitted documents or the confirmatory certification issued by other financial institution must be required.
(c) requiring that the first payment is carried out through an account held by the Client in his name with a credit institution authorized in the EEA Member State or the third country which imposes equivalent requirements to those laid down in the laws of the United States.
- High-risk Clients and their transactions should be reviewed more closely at account opening and more frequently throughout the term of their relationship with the Company. Normally, the EDD for High-risk Clients will be executed on an annually basis.
7. SIMPLIFIED DUE DILIGENCE
- The simplified due diligence is allowed when the Client is representing a low ML/TF risk and in the following cases:
(1) the Client is a company whose securities are admitted trading on a regulated market in one or more EEA Member States, and other companies from third countries whose securities are traded in regulated markets, and which are subject to disclosure requirements consistent with EU legislation. in case of electronic money, where a limit of EUR 1,000 or an equivalent amount in foreign currency is imposed on the total amount transacted in a calendar year, except the cases set forth in Section 7 of these Procedures and the cases when an amount of EUR 500 or an equivalent amount in foreign currency, or more is redeemed in that same calendar year upon the electronic money holder’s request.
(2) in case of electronic money, if all the below listed risk-mitigation conditions are met:
a. the electronic money payment instrument may be used only in the United States.
b. the electronic money payment instrument is not reloadable, or – if loadable – has a maximum monthly payment transactions limit of EUR 150.
c. the maximum amount stored in the electronic money payment instrument does not exceed EUR 150.
d. the electronic money payment instrument is used exclusively to purchase goods or services.
e. the electronic money stored in the payment instrument cannot be funded with anonymous electronic money.
f. the electronic money stored in the payment instrument cannot be redeemed by cash.
- Simplified due diligence cannot apply if a separate decision of the European Commission has been adopted on this issue.
- Simplified due diligence cannot apply if there exist circumstances when the conduction of the enhanced Client identification is required. If the regular monitoring of the client's business relationship reveals that the risk of money laundering and / or terrorist financing is no longer low, additional due diligence measures must be applied.
- Where it is established that the simplified due diligence can be used, the Company must apply the measures indicated in Annex One of the Procedures based on the risk-based approach.
- This notwithstanding, we must ensure that supporting documentation is available in our records. and may be made available if required by the relevant authorities.
8. ONGOING-MONITORING
8.1 After the proper due diligence procedure is undertaken and based on the results of the latter the Client is accepted, the further monitoring of the Client, its business relationship (where applicable), Monetary operations and Transactions must apply. Ongoing monitoring is carried out to ensure that our clients meet the requirements stipulated in these Procedure and our services are not used for any ML/TF purposes as well as to enable us to establish the possible ML/TF actions and undertake the respective preventative measures. Ongoing monitoring may not apply when the Client is financial institution.
8.2 To monitor all the Monetary operations and Transactions undertaken by the Client and be able to assess their consistency with the knowledge, business, and risk profile of the Client. During this procedure it must be assessed whether the risk profile, business or financial position of the Client changed throughout the year. Records should be amended to reflect these changes. Previous records should still be kept in file.
8.3 The Client Due Diligence measures should be also taken every time where the following circumstances reveal:
(1) when there are doubts about the veracity or adequacy of previously obtained identification data of the Client and/or the Beneficial owner and/or the representative of the Client (where applicable).
(2) in any other case when there are suspicions that the act of ML or TF is, was or will be performed.
8.4 We must ensure that supporting documentation of the ongoing monitoring of the Clients is available in our records and may be made available if required by the relevant authorities.
9. RECORDKEEPING
9.1. Company
The Company must keep the following records:
(1) Client Identification Records:
a. all records of steps taken to obtain identification records, as well as copies of evidence of the identity of the Clients as the case may be (the documents to be obtained and retained for the Client identification purposes are established in Annex Two to these Procedures).
b. all risk assessment records as well as the Client risk profile.
c. a standard application form must be completed for every new Client as well as for the existing Client where the identification of the Client is needed under these Procedures; the filled application form must be signed off by all the Clients and prospective Clients.
d. all records related to the ongoing monitoring of the Clients.
(2) Record of Transactions:
a. a record containing details of all transactions undertaken during an established Business relationship; this is to include a record of all work performed for or the services provided to the Clients.
b. Transaction records are to be kept in a form which will allow a satisfactory audit trail to be completed where necessary, and which may establish a financial profile of any. suspect Client.
c. records on internal and external Suspicious Monetary operations and Transactions reporting.
(3) Other Records:
a. evidence of the training programmed on ML/TF prevention whether in-house or external.
b. evidence of the proper acknowledgment of the Employees with these Procedures and their amendments as may be needed from time to time.
c. other records if required under these Procedures or the Law on the Prevention of Money Laundering and Terrorist Financing of the United States as well as other legal acts related to the prevention of ML/TF
9.2. Registers
The Company keeps the electronic Registers as defined following. Entries in the Registers must be executed in chronological without any delay, but not later than within 3 (three) business days as of the respective transaction is executed or the respective circumstances occurred. The Registers are managed and the respective entries in the Registers are made by the Officer unless other person(s) is(are) appointed by the managing director of the Company.
The following data must be filled in the Registers:
(1) name, legal form, registration address, code (if available) for legal person or its representative (where relevant): name, surname, date of birth, personal number (or another unique combination of characters assigned to the person for identification purposes, if the personal number is not available).
(2) data on the Monetary operation or Transaction: date, description of the assets used (e.g., monetary funds, real estate etc.) and its value, amount, currency.
(3) data on the payee: name, surname, date of birth, personal number (or another unique combination of characters assigned to the person for identification purposes, if the personal number is not available) for natural person and company name, legal form, registration address, code (if available) for legal person.
(4) data on the Beneficial owner (where applicable) for the Register of the Suspicious Monetary operations and Transactions as well as the Register of the Clients with whom Transactions or Business relationship has been terminated due to the circumstances related to the ML/TF or the infringement of these Procedures only: name, surname, date of birth, personal number (or another unique combination of characters assigned to the person for identification purposes, if the personal number is not available);
(5) criterion under which the Monetary operation or Transaction is considered as Suspicious Monetary operation or Transaction in accordance with the order of the Director of the FIU No V-240 of 5 December 2014 for the Register of the Suspicious Monetary operations and Transactions only.
(6) reasons for the termination of the Transactions or Business relationship for the Register of the Clients with whom Transactions or Business relationship has been terminated due to the circumstances related to the ML/TF or the infringement of these Procedures only.
• The Registers are managed in digital format. The Registers are stored on the servers of the Company and are accessible via the internal network of the Company only. There is possibility to print out the content of the Registers on paper and this possibility remains after the data is copied in another durable medium. The IT system will have back up function which will allow reversing the Registers. Registers’ data will be also stored on another server to duplicate all transactions as well as actions within the Company. The IT system allows duplicating information in less than 24 hours.
• Register data shall be stored for at least 8 years from the day of termination of transactions or other business relationship with the Client. The rules for the keeping of registers shall be established by the Government of the United States.
• All Client information and documentation must be kept for the period of 8 years as of the end of the Transactions or Business relationship with the Client, save to the business correspondence with the Client which must be kept for the period of 5 years as of end of the Transaction or Business relationship with the Client.
• The data of the Registers must be kept for the period of 8 years as of the end of the Transaction or Business relationship with the Client.
• Hong Kong PTM Limited, in performing ongoing monitoring of the Client’s business relationships, including investigation of the transactions concluded in the course of such relationships, must take into account any activity which they regard as likely, by its nature, to be related to money laundering and/or terrorist financing, and in particular complex or unusually large transactions and all unusual patterns of transactions which have no apparent economic or visible lawful purpose, and business relationship or monetary operations with Clients from third countries in which money laundering and/or terrorist financing prevention measures are insufficient or do not correspond to international standards. The results of investigation of the basis for and purpose of performance of such operations or transactions must be substantiated by documents and must be stored for 8 years.
• The documents confirming the monetary operation or transaction, or other legally binding documents related to the performance of monetary operations or conclusion of transactions must be stored for 8 years from the day of performance of the monetary operation or conclusion of the transaction.
9.3. Keeping Method
Records may be kept both in hard copies and in soft copies, save the Registers which are kept in digital format only. Backups of soft copies of all Monetary operations and Transactions undertaken are to be taken on a regular basis at least once a month. Certain original documents or certified copies of documents obtained are to be retained in hard copies.
10. IMPLEMENTATION OF ML/ TF PREVENTION MEASURES
The Company’s preventative ML/TF measures are adopted considering the latest supra-national and national risk assessment documents, including the documents indicated below which shall be reviewed and updated from time to time:
a. the results of the European Commission and national money laundering and terrorist financing risk assessment unless it is decided during the national money laundering and terrorist financing risk assessment not to comply with certain recommendations of the European Commission.
b. guidelines of the European Supervisory Authorities regarding the risks that should be considered and the measures that need to be taken in cases when it is appropriate to apply enhanced Client identification measures.
10.2. The managing director of the Company is responsible for the proper compliance of the Company with the requirements established by the Law on the Prevention of Money Laundering and Terrorist Financing of the United States as well as other legal acts related to the prevention of ML/TF. Therefore, the managing director must arrange the following:
(1) the preparation and approval of these Procedures as well as proper revision of these Procedures as may be needed from time to time.
(2) the appointment of the Officer and replacement of the Officer as may be needed from time to time as well as arrangement of the respective notification on the latter to the FIU.
(3) ensure the proper acknowledgment of the existing and new Employees with these Procedures as well as the amendments thereto as may be needed from time to time.
(4) ensure the proper training of the existing and new Employees on the ML/TF prevention measures prior to their commencement of the duties related to the ML/TF prevention as well as further periodical training, including the training in case of new ML/TF prevention regulation is issued and/or these Procedures are amended as may be needed from time to time.
(5) ensure the proper implementation of these Procedures in the Company, including but not limited to due diligence of the Clients; ML/TF risk assessment and management; ongoing. monitoring of the Clients; establishment, suspension and reporting of the Suspicious Monetary operations and Transactions; recording and keeping the ML/TF prevention- related information and documentation, including the proper maintenance and keeling of the Registers.
(6) other duties established under the Law on the Prevention of Money Laundering and Terrorist Financing of the United States and other legal acts.
10.3. When performing the above duties, the managing director of the Company may appoint other persons to be responsible for the duties on the ML/TF prevention in the Company. In such event, the managing director of the Company remains liable under the Law on the Prevention of Money Laundering and Terrorist Financing of the United States and the related legal acts for the proper fulfillment of the above duties.
10.4. The Officer is to be appointed by the managing director of the Company. The managing director of the Company may appoint an alternate the Officer during periods when the Officer is going to be unavailable for a period to ensure continuity in the Company’s obligations related to the ML/TF prevention. Upon appointment or replacement (whether temporary or permanent) of the Officer the FIU is to be notified on the latter within 7 (seven) calendar days.
10.5. The Officer is responsible for the oversight of all aspects of the Company’s ML/TF prevention activities and is the focal point for all such activity of the Company, including the Client Due Diligence and further ongoing monitoring of the Clients as well as the suspension and reporting to the FIU of the Suspicious Monetary operations and Transactions and all communication with the FIU.
10.6. If during the Due Diligence stage or later during the ongoing monitoring of the Client the Employee has any doubts regarding the Client or its financial activity, the Employee must apply to the Officer. The Officer must undertake the needed internal investigation actions and decide if the circumstances reported by the Employee raise high risk of ML/TF. The Officer decides if the Client who raised the doubts can be accepted, which risk category such Client must be assigned and if the enhanced due diligence and ongoing monitoring must be undertaken with respect of such Client. All decisions of the Officer as well as reasons for such decisions should always be documented and retained by the Officer on file.
10.7. Employees should always file a report to the Officer upon knowledge or suspicion of ML/FT, and it is the Officer who would then consider if a Monetary operation or Transaction must be suspended and reported to the FIU. If the Officer decides that the Monetary operation or Transaction reported to Officer by the Employee is not a Suspicious Monetary operation or Transaction and there is no need to suspend it and report to the FIU, the reasons of such a decision should always be documented and retained by the Officer on file.
10.8. Once an internal report on the Suspicious Monetary operation or Transaction is lodged with the Officer, the latter should then consider the report in the light of all other relevant information in the Company’s possession. The Officer is to determine whether the transaction gives rise to knowledge or suspicion that a client is or could be engaged in ML or TF. The Officer is not expected to investigate the transaction other than internally or to determine whether the funds are the proceeds of criminal activity.
10.9. If the Officer is in doubt as to the possibility of ML/TF involvement, he may seek guidance from the FIU. If the report on the suspicious Monetary operation or Transaction is not filed with the FIU, the Officer should document the reasons for such decision.
11. TRAINING POLICY
Hong Kong PTM Limited is subject to applicable US, EU, and international anti-money laundering (AML) laws and regulations. Hong Kong PTM Limited seeks to make sure that any updates to relevant legislation and technical standards are followed and that our processes are also updated accordingly. Hong Kong PTM Limited has established adequate internal controls, procedures, and guidelines, has appointed a compliance officer, and performs continuous monitoring to comply with Client due diligence standards and AML requirements:
• The level of training provided to individuals is to be appropriate to their role and seniority within Hong Kong PTM Limited. In any case all Employees must have the proper training on ML/TF prevention prior to the commencement of their duties at the Company which involve the ML/TF risk.
• The managing director of the Company is responsible for the proper performance of the duties related to the training of the Employees. The managing director of the Company may appoint other persons who will undertake all necessary measures for the proper training of the Employees.
• The CO shall ensure by introducing a complete employee’s education and training program that all employees are fully aware of their legal obligations according to inter alia:
a. The systems and procedures in accordance with this Manual and/or group-wide procedure manual.
b. The AML/CFT Act and the relevant AML//CFT Regulations as amended from time to time.
The timing and content of the training provided to the employees of the various departments will be determined according to the needs of Hong Kong PTM Limited. The frequency of the training can vary depending on to the amendments of legal and/or regulatory requirements, employees’ duties as well as any other changes in the financial system.
The training program aims at educating the Hong Kong PTM Limited’s employees on the latest developments in the prevention of Money Laundering and Terrorist Financing, including the practical methods and trends used for this purpose.
The training program will have a different structure for new employees, existing employees and for different departments of Hong Kong PTM Limited according to the services that they provide. On-going training shall be given at regular intervals to ensure that the employees are reminded of their duties and responsibilities and kept informed of any new developments. Although Directors and Senior Managers may not be involved in the day-to-day procedures, it is important that they understand the statutory duties placed on them, their staff, and the entity itself. Some form of high- level general awareness training is therefore suggested for those staff that may not be involved in dealing with Clients on a day-to-day basis.
• The CO provides advice and guidance to the employees of the Hong Kong PTM Limited on subjects whose duties include the handling of Clients’ business, are to be adequately trained with respect to the procedures and the provisions of the Prevention of Money Laundering Act, the relevant Regulations, and the relevant provisions in the Criminal Code of the United States.
• The managing director of the Hong Kong PTM Limited is responsible for the proper performance of the duties related to the training of the Employees. The managing director of Hong Kong PTM Limited may appoint other persons who will undertake all necessary measures for the proper training of the Employees.
Annex One
1.Simplified Due Diligence
1.1. The Company uses simplified due diligence in cases specified in Section 7 of the Procedures.
1.2. Using the simplified identification procedure, the Company collects only the below indicated information about the Client’s identity. In case the Client’s risk profile has changed, the Company must take additional measures to implement the standard due diligence or enhanced due diligence if necessary to manage and mitigate those risks appropriately.
1.3. Following information must be collected:
(1) as regards citizens of the United States:
a. name(s).
b. surname(s).
c. personal number.
(2) as regards foreign citizens.
a. name(s).
b. surname(s).
c. date of birth (if available – personal number or another unique combination of characters assigned to the person for identification purposes).
(3) as regards legal persons (both local and foreign):
a. corporate name.
b. legal form, main office (registered office and/or the headquarter in the place of the main interests).
c. code (registration number etc., if any).
d. the data of the Beneficial owner.
e. the activities of a legal person, the purposes, and the object of a business relationship,as well as the type of economic activities.
f. the governance structure and the nature of activity of a legal person.
1.4. When applying the simplified due diligence in cases specified in Section 7 of the Procedures, the Company obtains information indicated in point 1.3 of Annex One and also ensures that the first payment of the Client is performed from the account held in a credit institution, where the credit institution is registered in the EU Member State or in a third country which has set the requirements equivalent to those laid down in the laws of the United States and is monitored by competent authorities for compliance with these requirements.
1.5. In cases indicated in Section7 of the Procedures, the Company can deviate from the measures indicated in Sections 1.2-1.3 of Annex One, however has to perform ongoing monitoring of the Client’s Business relationship, including scrutiny of transactions undertaken throughout the course of that relationship to ensure that the transactions being conducted are consistent with the Company’s knowledge of the Client, the business and risk profile, and the source of funds and to ensure detection of complex or unusually large transactions and unusual patterns of transactions (the Company must analyses the grounds of performance and purpose of such operations or transactions, and execute the results of such analysis in writing).
1.6. Information can be collected either through the face-to-face contact or using electronic means.
Annex Two
1. Client Identification procedure
1.1. Identity of the Clients will be verified pursuant to the below established rules.
1.2. The Client must provide personal identification document (for natural persons) or the registration and/or other corporate documents (for legal persons).
1.3.This Section also applies to those cases where the Client is represented by another person. Usually, such representation is documented by the power of attorney. Where the Client is represented by another person, the Employee must identify and verify both the Client and the representative. In addition, the respective representation document (usually this will be the power of attorney) must be verified (it is expected that you will check if the person who issued the respective document had such capacity; the validity period of the representation document and the representation powers granted by such document). The representative shall provide personal document (ID or passport) to identify its personality. Should you have any doubts regarding the representation document submitted for the identification purposes, you must apply to the Officer who will assess the representation document submitted and will decide if the submitted document is acceptable for the identification purposes.
1.4. Where the legal person is represented by the managing director of such legal person or by other person who holds the right to represent the legal person under the respective corporate documentation, such situations is considered as the physical presence of the Client. However, the identification of the representative must be carried out.
1.5. The documents obtained for the identification of the Client must be sufficient to properly determine and collect the below data and information about the Client and the representative (where applicable).
1.6. Following information must be collected from the personal identification document or the registration document used for the due diligence purposes:
(1) as regards citizens of the United States:
a. name(s).
b. surname(s).
c. personal number.
d. photograph.
e. signature.
f. nationality.
(2) as regards foreign citizens.
a. name(s).
b. surname(s).
c. date of birth.
d. number of identification document or equivalent travel document, the place of its issue and the expiry date, or the number and the expiry date of a permit for permanent residence in a foreign state as well as the place and date of its issue (applies to foreigners permanently residing in a foreign country).
e. photograph.
f. signature.
g. nationality.
(3) as regards legal persons (both local and foreign):
a. corporate name.
b. legal form, main office (registered office and/or the headquarter in the place of the main interests).
c. code (registration number etc., if any).
d. registration extract and date of its issue.
e. the data of the Beneficial owner.
f. the activities of a legal person, the purposes, and the object of a business relationship,as well as the type of economic activities.
g. the governance structure and the nature of activity of a legal person.
2. Identification of the Beneficial owner
2.1. Where the Client is a legal person, the Beneficial owner as defined in Section 1 of the Procedures must be identified (may not apply when the Client is financial institution). In all cases, the identification of the Beneficial owner means the identification of the natural person or the group of the natural persons.
For this purpose, the Employee must request the Client to submit the documents which allow identifying.
the following personal data of the Beneficial owner:
(1) name.
(2) surname.
(3) personal number or another unique combination allowing to identify a person.
(4) nationality.
2.2. Such documents submitted by the Client must be certified in the Client’s file or application by the signature and the stamp of the Client, if holding a stamp is mandatory to the Client under the applicable laws. Documents may also be certified on the non-face-to-face basis using a qualified electronic signature.
2.3. In addition, the Employee must use the reliable and independent sources (e.g., Section 3 of the Procedure) for verification of the documents and information regarding the Beneficial owner submitted by the Client. The Employee also must ask the Client to specify the public sources where the data and documents regarding the Beneficial owner can be verified.
2.4.The following data of the Beneficial owner must be stored by the Company and available to be submitted to the FIU if required by the latter:
(1) the identity data (name, surname, personal number, or another unique combination, if the personal number does not exist).
(2) evidence on verification of the data and documents submitted by the Client in the reliable and independent sources.
(3) data on the management structure of the Client – legal person.
(4) records on the flows of the Client’s funds.
2.5. To ascertain whether the Client is acting on his own behalf or is controlled, the Employee must:
(1) verify whether the right to perform a Monetary operation on behalf of the Client has been granted to a person who is in clear business, professional or commercial relations with the Client.
(2) to verify if there are elements that do not correspond to the typical Monetary operations and commercial activity of the Client (e.g., more frequent payments in cash, increasing sums involved in Monetary operations, Payment for products or services that are not related to the Client's main activity).
(3) to observe if the Client provides requested information in good faith and does not avoid answering the questions.
3. Identification of the PEP
3.1. The Employee must ask the Client to indicate and provide relevant information to determine if the Client or the Beneficial owner is a PEP.
3.2. PEPs are prohibited from opening an account.
4. Identification of the Client registered in the Target territories.
4.1. In addition to the above data, where the Client is a legal person or other organization registered in the Target territory, the Client, and its representative (if applicable) must provide in writing the following information:
(1) current place of residence.
(2) postal address.
(3) contact information (valid telephone numbers, email addresses).
5. Information and documentation used for the identification purposes.
5.1. The documents submitted for the due diligence purposes must be either:
(1) the original documents; or
(2) the copies certified by the public notary.
5.2. The Employee must make and keep the copies of the identification documents and other documents submitted by the Client for the Client identification purposes when applying face-to-face identification procedure. In case hard copies are kept, such copies must be:
(1) signed by the Employee, indicating the position, name and surname of the Employee and the date.
(2) marked by the Employee as authentic by making an entry "True copy ".
(3) certified by the stamp of the Company, if holding a stamp is mandatory to the Company under the applicable laws.
5.3.Additional information obtained from the Third parties or additional sources must be documented and stored similarly to the copies of the personal identification documents or other due diligence documents as discussed above. Where the checks are made in the data basis or similar sources, the Employee must document the results of such searches/checks, sign and certify such documents in the same manner as the copies of the personal identification documents and store similarly to the copies of the personal identification documents or other due diligence documents.
Annex Three
1. Non-face-to-face identification measures
1.1. Identity of the Clients will be verified through pursuant to the Procedures, including non-face-to-face identification measures established in Section 3 of the Procedures, and the below established rules applicable to physical and legal persons.
2. Identification of a physical person
The Client’s identity is established using electronic means of the Company, allowing direct view transmission when Client’s facial image and original identity document are captured using online view-streaming tool. This view-steaming tool complies with technical requirements set in Part 4 below.
In addition:
1) The Client uploads the proof of address (usually in the form of a utility bill).
2) The Company’s system verifies through the third-party database that the passport/ID card’s number is real, it matches the name, and that the person has no criminal history, or is compromised.
3) The information is manually reviewed by the Company’s Compliance team and only after this point the Client is allowed to use the account.
From time to time, the Company’s team may call the client on the phone number provided to confirm request.
3. Identification of a legal person
After the Company identifies the Client’s authorized representative in accordance with identification requirements applicable to physical persons:
Client provides the following information in an electronic account opening form:
- Name of legal entity (including name in original language).
- Legal form.
- Registered and business address.
- Registration number.
- Date of registration.
- E-mail, business telephone number, web address.
- Purpose of account and expected transaction types.
- Estimated incoming payment amount.
- Origin of funds declaration.
- Business activity.
- Beneficial owner declaration.
Client uploads the following documents:
a. For Clients recorded in the commercial register:
- An extract from the Commercial Register issued by the Registrar; or
- A written extract (procured by the Company) from a database managed by the registration authority; or - A written extract (procured by the Company) from a reliable, privately managed directory or database.
b. For Clients not recorded in the Commercial Register or an equivalent Register:
- The by-laws, founding acts or agreements, auditor’s certification, official authorization to exercise the activity or equivalent documents; or
- A written extract (procured by the Company) from a reliable, privately managed directory or database. Authorities must be identified by means of an appropriate by-law / resolution or other equivalent documents or sources. The extract from the Commercial Register, the certification by the auditor and the directory or database extract must be no more than one year old at the time of identification and must correspond to the current circumstances.
c. Client uploads identification documents of beneficial owner – electronic copy of passport/ ID card.
d. The Company’s system verifies through the third-party database that the provided information of legal entity and beneficial owner is real, it matches the name, and that the person has no criminal history, or is compromised.
e. The information is manually reviewed by the Company’s Compliance team and only after this.point the Client is allowed to use the account.
4. Technical requirements for non-face-to-face identification measures
4.1. The Company’s technical application used for non-face-to-face identification (where the facial image of the Client and the original of the identity document shown by the Client are captured by means of live image transmission), ensures the following:
4.1.1. A picture of the facial image of the Client is taken from the front (the image must contain the face and shoulders of the Client; the image must be clearly visible and distinguishable from the surrounding objects).
4.1.2. Live transmission of the photograph in the identity document presented is performed. The following parts of the document are captured:
4.1.2.1. Both sides of an identity card.
4.1.2.2. In the event of showing a passport, the page of the document containing the relevant natural person’s photograph and the passport cover.
4.2. The Company’s technical application ensures that the image capturing process is continuous and non- real-time image transmission is impossible.
4.3. The quality of live image transmission facilitates easy reading of information from the identity documents presented and ensure that the features of the person and the person whose photograph is on the identity document are clearly visible and do not raise any doubts.
4.4. If the non-face-to-face identification process using the Company’s technical application does not meet the requirements established in Points 4.1-4.3 above, the Company requires the Client to perform identification procedure once again.
4.5. The data collected during the non-face-to-face identification procedure are kept for the period of 8 (eight) years as of the end of the Transaction or Business relationship with the Client at the same format that were collected.
Annex Four
The following countries, territories and zones are considered as the Target territories under the Procedures:
(1) Andorra
(2) Anguilla
(3) Antigua and Barbuda
(4) Afghanistan
(5) Macau
(6) Aruba
(7) Azores
(8) Bahamas
(9) Bahrain
(10) Barbados
(11) Belarus
(12) Belize
(13) Bermuda
(14) Bosnia and Herzegovina
(15) Brunei
(16) Central African Republic
(17) Croatia
(18) Cuba
(19) the Democratic Republic of Congo
(20) Dominica
(21) Jersey
(22) Djibouti
(23) Ecuador
(24) Ethiopia
(25) Guernsey, Sark, Alderley
(26) Gibraltar
(27) Grenada
(28) Grenada
(29) Guatemala
(30) Honduras
(31) Jamaica
(32) United Arab Emirates
(33) Cayman Islands
(34) Kenya
(35) Kosovo
(36) Costa Rica
(37) Cook Islands
(38) Kuwait
(39) Lebanon
(40) Liberia
(41) Libya
(42) Liechtenstein
(43) Madeira
(44) Maldives
(45) Marshall Islands
(46) Mauritius
(47) Macedonia (North)
(48) Montenegro
(49) Mali
(50) Isle of Man
(51) Iran
(52) Iraq
(53) British Virgin Islands
(54) U.S. Virgin Islands
(55) Monaco
(56) Montserrat
(57) New Caledonia
(58) Nauru
(59) Niue
(60) Nicaragua
(61) Netherlands Antilles
(62) North Korea
(63) Panama
(64) Russian Federation
(65) Samoa
(66) San Marino
(67) Seychelles
(68) Saint Pierre and Miquelon
(69) Saint Kitts and Nevis
(70) Saint Vincent and the Grenadines
(71) Serbia
(72) Slovenia
(73) Somalia
(74) South Sudan
(75) Sudan
(76) Syria
(77) Island of Saint Helen
(78) Tahiti
(79) Turks and Caicos Islands
(80) Tonga
(81) Uruguay
(82) Ukraine
(83) Vanuatu
(84) Venezuela
(85) Yemen
(86) Zimbabwe
Annex Five
The Company prohibits to open accounts for Clients engaging in below activities, and Clients are not permitted to use the Company’s Services to facilitate any of the following activities:
• Marijuana/cannabis related businesses, Guns, Arms and ammunition, Precious metals services, Adult entertainment or Pornography, FX Services, Cash Transactions
• Internet gambling, casinos, gambling, or betting, including lottery tickets, casino gaming chips, off- track betting, memberships on gambling-related internet sites, and wagers at races.
• adult or adult-related services, including escort services, adult massage, or other adult-entertainment services; adult performers or webcam services, other obscene services.
• outbound telemarketing.
• buyers’ or discount clubs.
• items that may be counterfeit.
• items that may infringe or violate any copyright, trademark, right of publicity or privacy or any other proprietary right under the laws of any jurisdiction.
• items that promote hatred, violence, racial intolerance, or the financial exploitation of a crime.
• items that promote, support, or glorify acts of violence or harm towards self or others.
• sale, purchase live animals, seeds, or plants.
• purchase, sale or promotion of marijuana or marijuana paraphernalia, or items that may represent these uses.
• purchase, sale, or promotion of prescription medications.
• Purchase, sale or facilitate toxic chemicals.
• using the Company’s Products or Services for any illegal purpose, or in violation of any local, national, or international law, including, without limitation, laws governing intellectual property, taxation and other proprietary rights and data collection and privacy.
• using the Company’s Products or Services in any manner that could damage, disable, overburden, or impair the Company.
• using the Company’s Products or Services to support pyramid or Ponzi schemes, matrix programs, other “business opportunity” schemes or certain multi-level marketing programs.
• using the Company’s Products or Services to defame, harass, abuse, threaten or defraud others, or collect, or attempt to collect, personal information about users, registered recipients, or third parties without their consent.
• purchase, sale firearms or weapons including replicas and collectible items.
• participation in an organized criminal group and racketeering, including any offence set out in Framework Decision 2008/841/JHA.
• Terrorism, including any offence set out in Directive (EU) 2017/541 of the European Parliament and of the Council.
• Trafficking in human beings and migrant smuggling, including any offence set out in Directive 2011/36/EU of the European Parliament and of the Council and Council Framework Decision 2002/946/JHA.
• Sexual exploitation, including any offence set out in Directive 2011/93/EU of the European Parliament and of the Council.
• Illicit trafficking in narcotic drugs and psychotropic substances, including any offence set out in Council Framework Decision 2004/757/JHA.
• Illicit arms trafficking.
• Illicit trafficking in stolen goods and other goods.
• Corruption, including any offence set out in the Convention on the fight against corruption involving officials of the European Communities or officials of Member States of the European Union and in Council Framework Decision 2003/568/JHA.
• Fraud, including any offence set out in Council Framework Decision 2001/413/JHA.
• Counterfeiting of currency, including any offence set out in Directive 2014/62/EU of the European Parliament and of the Council.
• Counterfeiting and piracy of products.
• Environmental crime, including any offence set out in Directive 2008/99/EC of the European Parliament and of the Council or in Directive 2009/123/EC of the European Parliament and of the Council.
• Murder, grievous bodily injury.
• Kidnapping, illegal restraint and hostage-taking.
• Robbery or theft.
• Smuggling.
• Tax crimes relating to direct and indirect taxes, as laid down in national law.
• Extortion.
• Forgery.
• Piracy.
• Insider trading and market manipulation, including any offence set out in Directive 2014/57/EU of the European Parliament and of the Council.
• Cybercrime, including any offence set out in Directive 2013/40/EU of the European Parliament and of the Council