Anti Money Laundering and Counter Terrorist Financing Policy

Introduction

The purpose of this Anti Money Laundering (“AML”) and Counter Terrorist Financing (“CTF”) Policy (“Policy”) is to ensure that any money laundering risks identified by us are appropriately mitigated. This means having adequate systems and controls in place to mitigate the risk of our services being used to facilitate any financial crimes. We also would like to provide the basic guidelines to our users, irrespective of their location, regarding essential AML/CFT requirements.

This Policy (including any supplementing AML/CFT procedures) will be periodically reviewed, with timely and suitable changes made as the risks evolve over time.

Administrative Information

Republic of Croatia:

• Legal name: Lonvest Platform d.o.o.
• Registered address: Zagreb (Grad Zagreb), Lovinčićeva ulica 3.
• Company number: 081501022
• Services: matching the applications of lenders and borrowers.
• If you have any questions regarding this Policy, please contact us at [email protected].

1. Customer Due Diligence Measures

The Customer Due Diligence Measures (“CDD”) measures are taken and performed to the extent necessary considering the Customer’s risk profile and other circumstances in the following cases:

• upon establishment of the Business Relationship and ongoing monitoring of the Business Relationship;
• upon verification of information gathered while applying CDD measures or in the case of doubts as to the sufficiency or truthfulness of the documents or data gathered earlier while updating the relevant data;
• upon suspicion of money laundering or terrorist financing, regardless of any derogations, exceptions or limits provided for in this policy and applicable legislation.

We do not establish or maintain the Business Relationship and do not perform transactions if:

• we are not able to take and perform any of the required CDD measures. In such cases, we will carry out the money laundering and/or terrorist financing threat assessment. After detecting the risk of money laundering and/or terrorist financing, we will report the suspicious monetary operation or transaction to the AML Office (Croatia);
• we have any suspicions that our services or transaction will be used for ML, TF, or violation of sanctions;
• the risk level of the Customer does not comply with our risk appetite.

We do not accept as Сustomers:

• persons or entities from Afghanistan, Angola, Algeria, Bahamas, Bangladesh, Bolivia, Botswana, Burma (Myanmar), Burundi, Cambodia, Chad, Gvineja, Côte D’ivoire, Crimea (Ukraine region), Cuba, Democratic People’s Republic of Korea, Egypt, Equatorial Guinea, Eritrea, Ghana, Guinea Bissau, Guyana, Iceland, Iran, Iraq, Haiti, Lao PDR, Lebanon, Libya, Mali, Mongolia, Morocco, Myanmar, Nepal, Nicaragua, North Macedonia, Pakistan, Panama, Russia, Qatar, Saudi Arabia, Somalia, South Sudan, Sudan, Syria, Trinidad and Tobago, Uganda, United States, Vanuatu, Venezuela, Yemen, Zimbabwe;
• persons or entities from disputed territories as they do not produce recognised official documents, these include: Donetsk People’s Republic (DPR)/Luhansk People’s Republic (LPR), Pridnestrovian Moldavian Republic, Nagorno-Karabakh Republic, Republic of Abkhazia, Republic of Somaliland, Republic of South Ossetia, Turkish Republic of Northern Cyprus, Passports issued by the Russian Federation in Crimea and passports issued by the Russian Federation to the residents of Donetsk and Luhansk regions of Ukraine do not qualify for verification, Republic of Kosovo, Sahrawi Arab Democratic Republic, Republic of Artsakh;
• politically exposed persons and their family members/close associates.

Persons or entities from jurisdictions where a particular license or permit is required will not be accepted as Customers if we have not received such a permit or license.

In the case of receiving information in foreign languages within the framework of CDD measures implementation, we may request to demand translation of the documents to another language applicable for us (usually it is English). The use of translations may be avoided in situations when the original documents are prepared in a language applicable for us.

2. Customers Onboarding and Know Your Customer Procedure

Individuals. The Customer shall go through the onboarding procedure with software provided by a third party with whom we have contractual relationships. The Customer, who is a natural person, is not allowed to use representatives in the course of the Business Relationship with us.

The Customer shall create an account on our website by providing the following:

• verifying email;
• verifying phone number;
• choosing and confirming their password;
• confirming the acceptance T&C.

The Customer may further log into their account via entering to our website their email, password and 2FA code.

The Customer shall pass the verification via software solution provided by a third party with whom we have contractual relationships via the following steps:

• to fill out the KYC questionnaire electronically through such software solution; submission of the completed KYC form by the client in electronic form is the client's signature.
• to take: (i) the photo of their identification document (ID); (ii) liveness selfie; (iii) to upload the documents which prove their address and/or source of funds when applicable.

If there’s no additional actions needed – we will notify you (through the website) that the onboarding procedure has passed successfully, and you may use our services.

If any of additional actions needed – our customer support specialist shall contact you and perform actions needed.

If you do not provide us with any of the requested documents or provide incomplete information/documents, we will not be able to establish a Business Relationship with you. In the event that a Business Relationship has already been established, we have the right to terminate it.

Legal entities. The Customer’s representative shall go through the onboarding procedure with software provided by a third party with whom we have contractual relationships. The Customer’s representative shall create an account on our website by providing the following:

• general information, including: full legal name; trade name legal form; date of incorporation; company number; VAT number; TIN; date of issue and validity; registered address;
• contact information, including: operating address; email; phone number; website; representative; representative’s position;
• bank details, including: bank name; bank address; account number; IBAN; SWIFT/BIC code;
• Beneficial Owners’ information: full name; date of birth; tax number; place of birth; type of identity document; identity document number; issuing authority; nationality; identity document’s date of issue and expiration; residential address; interest/shares amount; annual income in EUR; US person status confirmation; source of wealth;
• officers’ information, including: total number of officers in the company; full name; date of birth; tax number; place of birth; type of identity document; identity document number; issuing authority; nationality; identity document’s date of issue and expiration; residential address; email; phone number;
• business activity information, including: industry; annual net profit for the last financial (fiscal) year in EUR; number of employees; description of typical customers and provided services/goods; source of funds;
• account activity information: purpose of account opening; expected monthly deposit volume in EUR; expected monthly withdrawal volume in EUR; expected monthly trading volume in EUR;
• licenses, permissions and AML regulation information: confirmation whether the Customer currently holds any license; confirmation whether the Customer has held any licenses in the past; confirmation whether the Customer’s business activity requires any kinds of permissions, registrations or authorisations; confirmation whether the Company is subject of AML regulation in the country of incorporation; confirmation whether the Company has an AML compliance program; compliance officer’s full name, phone number and email (if applicable);
• declaration statements.

The Customer shall pass the verification via software solution provided by third party with whom we have contractual relationships via the following steps:

• to fill out the KYC questionnaire electronically through such software solution; submission of the completed KYC form by the client in electronic form is the client's signature.
• to provide the following documents:
  • the Customer’s extract of registry card or registration certificate of the relevant register or an equivalent document;
  • the Customer’s list of beneficiaries or other equivalent document (e.g., extended registry card);
  • the Customer’s articles of association;
  • the Customer’s license (if applicable);
  • the Customer’s financial statements (if available);
  • the Customer’s AML policy (if applicable);
  • representative’s documents: to take the photo of their identification document (ID) (certified); to upload the documents which prove their address;
  • to provide directors'/shareholders’ documents: to take the photo of their identification document (ID) (certified); to upload the documents which prove their address.
  • to provide Beneficial Owner’s documents: identity documents, proof of source of funds document.

If there’s no additional actions needed – we will notify you (through the website) that the onboarding procedure has passed successfully, and you may use our services.

If any of additional actions needed – our customer support specialist shall contact you and perform actions needed.

If you do not provide us with any of the requested documents or provide incomplete information/documents, we will not be able to establish a Business Relationship with you. In the event that a Business Relationship has already been established, we have the right to terminate it.

3. Monitoring of Business Relationships

We monitor our customer's activity through the application of the following measures:

• monitoring and scrutinizing the compliance of customer’s business operations with the intended nature and purpose of the business relationship and transaction;
• monitoring and scrutinizing the compliance of sources of funds with the intended source of funds the customer has indicated when establishing the business relationship and when performing the transactions with the customer (a) from a high-risk third country, (b) who performs complex and/or unusual transactions, (c) who performs a suspicious transaction, (d) who performs a large cash transaction;
• monitoring and scrutinizing the compliance of customer’s operations or transactions with the customer’s usual scope of business operations or transactions, and
• regularly monitoring and updating the collected documents and information on customers, beneficial owners of customers and the customer risk profile and scrutinizing the data indicating whether the customer or the beneficial owner of the customer has become or ceased to be a politically exposed person.

Transaction Monitoring. In the course of the ongoing transaction monitoring, we apply the following measures:

• screening i.e., monitoring transactions in real time;
• monitoring i.e., analyzing transactions later.

In some cases we need to identify the source and origin of the funds used in transactions. The need to identify the source and origin of funds depends on our Customer’s previous activities as well as other known information. Thereby the identification of the source and origin of the funds used in transaction shall be performed in the following cases:

• the transactions do not correspond to the information previously known about the Customer;
• we want to or should reasonably consider it necessary to assess whether the transactions correspond to the information previously known about the Customer;
• we suspect that the transactions indicate criminal activities, ML or TF or that the relation of transactions to ML or TF is probable, incl. complicated, high-value and unusual transactions and transaction patterns that do not have any reasonable or obvious economic or legitimate purpose or are uncharacteristic of the specific features of the business in question.

We also need to establish your source of funds used for making transactions in case when the total transactions amount within a 24 hour period exceeds 10 000€ or its equivalent in other assets.

Please note that we are required to report suspicious and/or large cash transactions to regulators in Croatia.

Updating the Customer's Data. Our relevant employees are obliged to check the relevance of the data collected in the course of CDD measures implementation (the “Customer's Data”). This check is performed with the following measures:

• asking the Customer for confirmation, that the Customer's Data used for the Customer's identification is up to date;
• the Customer's Data verification in accordance with the requirements established for data collection and verification.

The aforementioned check shall be performed in the following cases:

• check shall be performed due to the time passed from the moment of the Customer's Data collection;
• the Customer notifies about changes in the Customer's Data;
• when the Customer's behavior (e.g. amount of transactions, payment institution(s) used, partners involved, etc.) changes and it affects the Customer's Data or the Customer’s risk score.

In addition to aforementioned, Customers are continuously screened against watchlists (incl. PEP, Sanctions and Adverse Media) by our employees.

4. Cooperation and Exchange of Information

We cooperate with supervisory and law enforcement authorities in preventing money laundering and terrorist financing, thereby communicating information available to us and replying to queries within a reasonable time, following the duties, obligations and restrictions arising from legislation. For any relevant requests please contact us at: [email protected].