The AML policy of Sky Anvil Rus LLC is committed to high standards of anti-money laundering (AML) and combating the financing of terrorism (CFT). In this connection, the Company carries out a set of measures aimed at detecting and combating money laundering in accordance with international requirements on this aspect.

Customer identification and verification

1.1. According to AML and KYC (“Know Your Customer”) policies, the Company identifies and verifies the Customer based on documents and data, both at the beginning and during the process of providing services and selling goods to the Customer.

1.2. During the registration process, the Client provides the Company with identifying information, which includes the Client’s full name, date of birth, country of residence and e-mail.

1.3. After receiving the identifying information, the Company shall verify the Client by requesting the relevant documents.

1.3.1. The document designed to verify the Client’s identity is a high quality scanned copy or photo of a passport, driver’s license or any other national identity document.

1.3.2. A high quality scanned copy or photo of a utility bill or bank statement no older than 3 months is the document that proves the address of residence.

1.4. At the request of the Company, the Client must provide a scanned copy or photo of the front and back side of the payment card. The full name of the cardholder, the card expiration date, and the first 6 and last 4 digits of the card number should be visible on the front of the card. The cardholder’s signature must be visible on the back, the CVC2/CVV2 code must be closed.

1.5. The Company conducts regular due diligence on the Client in order to determine the risk it may bear and to identify changes in information about the Client.

1.6. If the Company believes that cooperation with the Client has a high risk of money laundering or terrorist financing, the Company has the right to request any other additional documents that it considers necessary in this situation.

1.7. The Client must immediately report any changes in personal information or contact information.

Payment policy

2.1. In order to minimize the risk of money laundering and terrorist financing, the Company does not accept cash as payment for Goods or Services and does not make cash refunds under any circumstances.

2.2. The Company reserves the right to refuse to process a transaction at any stage if it is suspected that the transaction is in any way connected to money laundering or criminal activity.

2.3. According to international law, the Company does not inform the client that its suspicious activity has been notified to the relevant authorities.

2.4. During replenishment operation, the name of the sender of funds must fully correspond to the name specified when registering an account. Payments from third parties are not accepted.
2.5. The company requires strict adherence to the generally accepted payment procedure. The money can be returned to the same account and in the same way that the payment was made. When returning a payment, the name of the recipient must exactly match the name of the payer. If the payment was made by bank transfer, the funds can be returned only by the same bank transfer to the same bank and to the same account from which the payment was made. If the payment was made by means of electronic payment system, the funds can be returned only by means of electronic payment to the same system and to the same account from which the payment was made.

2.6. For execution of procedures to combat money laundering, the return of funds is carried out only in the currency in which the payment was made.2.7. The Company keeps data on transactions for 5 years from the date of completion of trading activities with the Client.

Employee training

3.1. The Company designates a Money Laundering Compliance Officer who is fully responsible for the Company’s compliance with CFT and AML policies, for developing and implementing the Company’s AML program, for training employees in money laundering prevention, and for receiving, reviewing and maintaining internal reports of suspicious activity.

3.2. All employees and managers of the Company undergo a thorough screening process when they are hired by the Company.

3.3. Employees who work with clients and are involved in verifying, detecting and tracing money laundering offenses are trained in anti-money laundering. An AML training plan is also provided to all new employees. Anti-Money Laundering training includes training in identifying suspicious activity, preventing, detecting and reporting money laundering and terrorist financing offenses.

3.4. The Money Laundering Enforcement Officer must be provided with reports of all violations of the Company’s AML policy, if any. Where this policy has been violated by the Money Laundering Enforcement Officer himself/herself, reporting of such a violation must be provided to the Company’s manager.

Making changes to this AML policy

The Company reserves the right to change this AML Policy at any time, so please review it regularly. If the Client continues to use or visit the site, the Client automatically agrees to the changes in this Policy.