Version 1.0. – 25/06/2025
TABLE OF CONTENT
Money Laundering is the process of disguising the origin of the proceeds of crime. Terrorist financing provides funds for terrorist activity. The use of products and services by money launderers and terrorists exposes METASWAP SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (METASWAP) to significant criminal, regulatory and reputational risk.
This Anti-Money Laundering and Countering Terrorism Financing Policy (hereinafter referred to as the "AML Policy" or the “Policy”) is designed to provide direction to staff on the approach and management of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) within METASWAP. This Policy supports management’s objective of mitigating the following risks:
This Policy applies to all individuals working at all levels of METASWAP, including senior managers, officers, directors, employees, consultants, contractors, trainees, homeworkers, part- time and fixed-term workers, casual and agency staff, all of whom are collectively referred to as
„staff‟ in this document.
Senior management of METASWAP will provide direction to, and oversight of, the AML and CTF strategy as well as apply a risk-based approach across the business.
METASWAP will enforce a strict anti-money laundering policy with zero tolerance for money laundering activities. METASWAP defines money laundering as any activity that is carried out in an attempt to misrepresent the source of funds actually acquired through illegal processes as funds that were acquired through lawful sources/activities.
All METASWAP’s partners will be obligated to comply with METASWAP’s Policy and with all applicable anti-money laundering laws. Failure to comply can result in severe consequences such as criminal penalties and heavy fines.
The purpose of this Policy is (i) to establish the principles and standards that must be adhered to by METASWAP in relation to the prevention of money laundering and terrorist financing and compliance with international sanction programs, (ii) to define roles and responsibilities of the Company’s officers and employees in this area, (iii) to establish the procedures that must be undertaken by the Company, and (iv) to define the essential features of the governance.
This Policy is enacted and maintained by the director of METASWAP (the “Director”).
The METASWAP’s AML/CTF procedures will be in line with the requirements of the Republic of Poland and EU:
In the context of AML compliance, it is essential for METASWAP to be aware of and actively avoid involvement in three primary categories of offenses related to money laundering. These offenses not only carry severe legal consequences but also pose significant risks to the firm's reputation and operational integrity. The three broad groups of offenses are as follows:
Description: This offense occurs when an individual or entity knowingly participates in activities that assist in concealing the origin, nature, location, disposition, movement, or
ownership of criminal property. This can include aiding in the acquisition, use, or possession of such property with the knowledge that it represents the proceeds of criminal conduct.
Examples: Common forms of knowingly assisting include engaging in transactions that help launder money, setting up complex structures to hide the true ownership of assets, or facilitating the movement of funds through multiple jurisdictions to obscure their origins.
Description: This offense involves the failure to report to the relevant authorities when an individual or firm has knowledge or suspicion, or there are reasonable grounds to suspect, that another person is engaged in money laundering. The obligation to report such activities is a fundamental requirement of AML regulations.
Examples: Failure to report might include ignoring clear signs of suspicious activity, such as large cash transactions, sudden changes in behavior, or the use of offshore accounts without a legitimate business purpose. It can also involve overlooking discrepancies in the information provided by clients that raise red flags about the legitimacy of their funds.
Description: Tipping off refers to the act of informing someone who is the subject of a money laundering investigation that they are being investigated, thereby potentially compromising the investigation. Prejudicing an investigation involves any action that could obstruct or hinder the investigative process, including the destruction of relevant documents or alerting third parties.
Examples: This could include an employee warning a client that their transactions are under scrutiny, thereby giving them the opportunity to alter or destroy evidence. It could also involve sharing confidential information about an ongoing investigation with unauthorized individuals.
There can be considerable similarities between the movement of terrorist property and the laundering of criminal property, as both processes involve the concealment of the origin, destination, or purpose of funds to evade detection by authorities. In many cases, terrorist groups maintain close connections with organized criminal networks, leveraging these relationships to generate or move funds through illegal activities such as drug trafficking, smuggling, or fraud. These overlapping strategies make it challenging for financial institutions and law enforcement agencies to distinguish between the two types of financial flows.
However, there are two significant differences between terrorist property and criminal property that pose unique challenges for detection and prevention:
Description: Unlike large-scale criminal enterprises that often deal with substantial sums of money, terrorist activities can be financed with relatively small amounts of money. For instance, the funds required to carry out a single terrorist act can be minimal, making these transactions less likely to raise red flags within financial systems. This presents a significant challenge in tracking terrorist property because it requires institutions to be alert to even the most minor and seemingly innocuous transactions, which can easily be overlooked amidst the vast volume of daily financial activity.
Examples: Terrorists may utilize low-value transactions or a series of small payments to accumulate the necessary resources for an attack. These transactions can be spread across multiple accounts, jurisdictions, or financial instruments, further complicating detection efforts. Microfinancing of terrorism can also involve everyday consumer purchases, making it indistinguishable from normal financial behavior.
Description: One of the most challenging aspects of combating the financing of terrorism is that terrorist organizations can be funded through legally obtained income. This includes revenues from legitimate businesses, salaries, and, critically, charitable donations. Funds raised for humanitarian or religious purposes can be diverted to finance terrorist activities,
often without the donors’ knowledge. This makes it incredibly difficult to pinpoint the exact moment when these legitimate funds cross the line and become terrorist property.
Examples: Charitable organizations, especially those operating in conflict zones or regions with weak governance, are particularly vulnerable to exploitation. Terrorist groups may establish or infiltrate charities to funnel funds toward their operations. In some cases, donors may be unaware that their contributions are being misused, while in other instances, fundraising campaigns may be designed to appear entirely legitimate, masking their true intent. This complicates the task of financial institutions and regulators, as distinguishing between legitimate charitable activity and terrorist financing requires in-depth knowledge and sophisticated monitoring techniques.
The following definitions are established for the purposes of this Policy:
✔ International sanction and programs: Instruments of a political, diplomatic and economic nature used by international institutions and countries to exert influence in areas such as the prevention and pursuit of terrorism, support and defense of human rights and civil liberties, deterrence of possible armed conflicts or the prohibition of the development of weapons of mass destruction.
✔ General Inspector of Financial Information (GIIF): The Polish national Financial Intelligence Unit (FIU), responsible for implementing measures to prevent money laundering and terrorist financing, aimed at creating an effective national anti-money laundering system and ensuring its proper functioning. The GIIF also conducts pre-trial investigations related to the legalization of funds and property derived from criminal activities. The GIIF is the main state institution responsible for coordinating the cooperation of institutions involved in the implementation of anti-money laundering prevention measures.
✔ Virtual currency: a value represented in the digital form, which is digitally transferable, preservable or tradable and which natural persons or legal persons accept as a payment instrument, but that is not the legal tender of any country or funds for the purposes of Article 4(25) of Directive (EU) 2015/2366 of the European Parliament and of the Council on payment services in the internal market, amending Directives 2002/65/EC, 2009/110/EC and 2013/36/EU and Regulation (EU) No 1093/2010, and repealing Directive 2007/64/EC (OJ L 337, 23.12.2015, pp 35-127) or a payment transaction for the purposes of points (k) and (I) of Article 3 of the same Directive.
Money laundering and terrorist financing are universal globalized phenomena that take advantage of the international economy and the gradual elimination of barriers to trade globally, calling for a coordinated global response by the international community and the financial sector to prevent the sector being used for illicit purposes. The Company recognizes the importance of the fight against money laundering and terrorist financing as it affects essential aspects of social life. METASWAP will always fully cooperate with the relevant authorities in this area.
This Policy has been adopted to ensure that METASWAP complies with the rules and regulations set out in Polish Anti-Money Laundering and Counter-Terrorism Financing Act, in European Banking Authority (the “EBA”), and other international and local Laws and regulations.
The following principles reflect the minimum METASWAP’s expectations of the Policy as a whole. These principles are mandatory and must always apply.
METASWAP will not accept counterparties where the necessary data is not available, or which fall into one of the METASWAP’s agreed categories of prohibited counterparties. Prohibited counterparties are as follows:
1 That have a link to the prohibited country or to individuals or legal resident or incorporated in the prohibited country or are related to the government or the official institutions of the state (even if they are resident outside the prohibited country).
The following categories of clients will only be accepted with prior authorization by the senior management of METASWAP:
METASWAP identifies and follows sanction programs and financial countermeasures, monitors the international sanction programs issued by the Republic of Poland, UN, EU and OFAC that might affect the activities of METASWAP.
METASWAP assesses risks and manages to determine the extent to which a business relationship or activity may be affected by international restrictions, and approach must be taken into account in risk assessment methodology.
METASWAP refrains from conducting business relationships with restricted persons and no direct or indirect relations shall be established with persons who are subject to international restrictions. To this end, appropriate and up to date knowledge of counterparties, their activity, and other persons and carrying on relationships with METASWAP should be obtained.
METASWAP senior management will allocate a senior individual to be the Money Laundering Reporting Officer (MLRO) as required by the Money Laundering Regulations (MLR).
The MLRO will have overall responsibility for the establishment and maintenance of the METASWAP’s AML/CTF systems and controls and will report to the METASWAP’s senior management.
METASWAP has an appointed MLRO who reports directly to the senior management.
The MLRO, with the support of the senior management, is responsible for ensuring that METASWAP meets the AML compliance requirements and forms the second line of defense. The MLRO oversees the AML systems and controls.
The main activities of the MLRO comprise, but are not limited to, the following:
financial institutions
As long as METASWAP does not appoint (hire) other senior officers and employees responsible for implementation and application of compliance procedures at METASWAP and subordinate to MLRO, all the duties and obligations of such senior officers and employees within the first and the second line of defense shall be directly enforced by the MLRO and the Director.
The internal and external audit of METASWAP’s activities forms the third line of defense.
As long as METASWAP does not hire an internal auditor, the audit function in respect of METASWAP shall be performed by an external auditor engaged by the Director of METASWAP.
The external auditor shall be appointed in any cases prescribed by the AML Law or other applicable legislation.
The role of the auditor is conducting independent analysis of METASWAP’s policies and procedures for the purpose of identifying possible or actual violations of legislation and suggesting amendments which would make METASWAP’s activities and documents compliant with the law.
The MLRO shall organize internal and external AML/CTF trainings for the employees responsible for the AML/CTF compliance at METASWAP.
The MLRO shall take reasonable measures and ensure that at least once a year the employee complete an external educational course or program related to AML/CTF issues. If necessary, the MLRO shall ensure that METASWAP covers the educational expenses of the employees related to completion of such educational courses and programs.
The choice of the particular course or program is made by the MLRO in accordance with the areas of study covering AML/CTF training provided in this Section of the Policy. The chosen course or program shall not duplicate the course or program completed by the employees in the previous year.
The course or program chosen by the MLRO shall prescribe at least 30 academic hours of study.
The completion of the course or program shall be confirmed by the respective certificate issued by the educational organization.
The Director shall take reasonable measures and ensure that at least once a year the MLRO of METASWAP conducts an internal AML/CTF training for all other employees and officers of METASWAP responsible for the compliance issues at METASWAP.
The subjects of the internal AML/CTF training shall be chosen by the MLRO of METASWAP in accordance with the approved areas of study covering the AML/CTF training.
The internal training carried out by the MLRO of METASWAP shall provide for at least 20 academic hours of study.
The MLRO shall at least twice a year provide the Director of METASWAP with the list of the upcoming educational courses and programs related to AML/CTF and together with the Director approve the educational plan for the upcoming half-year.
METASWAP may make use of an external service provider to screen applicants against recognised Sanctions Lists and Politically Exposed Persons (PEPs) lists. Individuals will be screened on on-going basis as well as on initial sign up.
METASWAP will take all required steps to ensure that all customers with whom a business relationship is established are screened against relevant notices published by:
Information leading to “fuzzy matches” will be investigated further, for example where the match was related to a name which can be deemed as popular, and this will be compared against the other information that is collected at point of registration. The full evaluation of the customer’s data will provide a result. Any confirmed matches to sanctions lists will be declined or closed.
METASWAP will screen customers against PEP lists that will help to structure information about PEPs.
The definition of a 'PEP' is an individual that:
The company does not onboard PEPs due to the increased risk they represent in terms of potential involvement in bribery, corruption, and other financial crimes.
METASWAP establishing a relationship with any client (or any other counterparty) shall apply the following procedures:
Client Due Diligence Process includes the following specific parameters:
Client Acceptance Procedures
METASWAP adheres to the following principles in deciding whether a client of METASWAP shall be accepted (approved):
Client Due Diligence (CDD) measures are required for verifying the identity of a new or existing client as a well-performing risk-based ongoing monitoring of the business relationship with the client. The CDD measures consist of 3 levels: simplified, standard, and enhanced due diligence measures, as specified below.
The CDD measures are taken and performed to the extent necessary considering the client's risk profile and other circumstances in the following cases:
Achieving CDD is a process that starts with the CDD measures implementation. When that process is complete, the client is assigned with a documented individual risk level which shall form the basis for follow-up measures, and which is followed up and updated when necessary.
METASWAP has applied CDD measures adequately if METASWAP has the inner conviction that they have complied with the obligation to apply due diligence measures. The principle of reasonability is observed in the consideration of inner conviction.
This means that METASWAP must, upon the application of CDD measures, acquire the knowledge, understanding and assertation that they have collected enough information about the client, the client's activities, the purpose of the business relationship and of the transactions carried out within the scope of the business relationship, the origin of the funds etc., so that they understand the client and the client's (business) activities, thereby taking into account the client's risk level, the risk associated with the business relationship, and the nature of such relationship.
Such a level of assertation must make it possible to identify complicated, high-value, and unusual transactions and transaction patterns that have no reasonable or obvious economic or legitimate purpose or are uncharacteristic of the specific features of the business in question.
At point of registration within the website or mobile application, METASWAP will capture the following customer information of an individual:
At this stage, METASWAP will screen applicants against sanctions and PEP lists.
METASWAP will only permit one e-wallet per person and so the details provided will be checked against the existing customer database to confirm that they do not already hold an account, and they were not previously unsuccessful.
In order to identify the client, the client shall provide METASWAP with a valid identity document. If the client refuses to provide a valid identity document, the client shall not be accepted.
The following valid identity documents may be used as the basis for the identification of an individual:
The first credible and independent source used for the identification of the client is always an identity document specified above or a colored and legible copy/image of such a document.
The following information obtained is the second reliable and independent source used for the identification of the client:
✔ the client's photo (selfie) with an identity document;
✔ proof of address
✔ information for checking the data directly associated with the person (e. g. place of work, residence, or study).
The following documents can be used as the proof of address:
relationship with METASWAP which contains the full name of the client and his full residential address.
The name and address of the client shall be clearly visible on a document provided by the client as a proof of address.
METASWAP shall not accept screenshots and photos of the monitor screen.
METASWAP identifies the client which is a legal entity and their representative and retains the following data on the client:
METASWAP verifies the correctness of the client's data specified above using information originating from a credible and independent source for that purpose. Where METASWAP has access to the commercial register, register of non-profit associations and foundations or the data of the relevant registers of a foreign country, the submission of the documents specified does not need to be demanded from the Client.
The identity of the legal entity and the right of the legal entity's representation can be verified on the basis of a document specified above, which has been authenticated by a notary or certified by a notary or officially, or on the basis of other information originating from a credible and independent source, including means of electronic identification and trust services for electronic transactions, thereby using at least two different sources for verification of data in such an event.
The representative of the legal entity shall be identified as the client who is a natural person in accordance with the Policy. METASWAP must also identify and verify the nature and scope of the right of representation.
The name, date of issue and name of issuer of the document that serves as a basis for the right of representation must be ascertained and retained, except in case, when the right of representation was verified using information originating from the relevant register (e. g. the commercial register, register of non-profit associations and foundations or the relevant register of a foreign country).
METASWAP must observe the conditions of the right of representation granted to the legal entity's representatives and provide services only within the scope of the right of representation.
METASWAP should accept the clients/counterparties based on the risk they are likely to impose. The aim is to identify clients who are likely to bear a higher-than-average risk of money laundering or terrorist financing.
For this purpose, METASWAP classifies the clients into three categories:
Depending on the classification of the client, the appropriate due diligence process shall apply. That is, for High Risk clients a higher degree of due diligence shall apply.
The risk profiling is not a static element of the AML/CTF procedures of METASWAP. After METASWAP makes the on-board risk assessment of the client, the client can further be assigned to another risk category.
For instance, a client that has been classified as a Low Risk client during onboarding process may further be assigned to Medium or even High Risk client.
At the same time, a client that has been classified as a Medium Risk client can further be assigned to the group of Low Risk clients if, for example, the client changes the country of residence or the transactions of the client pose no ML/TF threat to METASWAP.
The following factors indicate that a client is a Low Risk client:
At the same time, the following factors indicate that a client is a High Risk client:
2 https://www.fatf-gafi.org/en/countries/fatf.html
METASWAP takes into account the following factors in determining the risk class of the client at the time of the acceptance procedures:
METASWAP also matches the location(s) of IP addresses used by the client with the location claimed by the client as a place of his residence.
Upon the verification of the client’s information, the client is classified as a Low Risk client if all the following factors are in place:
The client is classified as a Medium Risk client if the following factors are in place:
from the same IP address or from various IP addresses originating from the same city which match the city of client’s place of residence).
The client is classified as a High Risk Client if the following factors are in place:
originating from different countries, and the time frames between each login were so short that the client objectively could not move from one country to another within such a time frame.
If the client is classified as a Low Risk client, the client has the full access to the services of METASWAP and is subject to standard due diligence and transactions monitoring. All the transactions performed by such a client are presumed to be not suspicious unless METASWAP notices any suspicious changes in the behavior of the client or receives information about the illegal activities of the client.
If the client is classified as a Medium Risk client, the client has the full access to the services of METASWAP, however, such client is subject to enhanced due diligence (EDD) which requires METASWAP to conduct thorough monitoring of the client’s transactions. No presumption applies to the transactions of such a client, all his or her transactions are subject to close analysis. If METASWAP has any suspicions in relation to the respective transaction, METASWAP will immediately request the client to provide the supporting documents and information.
If the client is classified as a High Risk client, such client is denied access to the services of METASWAP unless the MLRO of METASWAP approves such a client and allows him to use the services of METASWAP. The MLRO Officer shall not approve the High Risk client if such client is a person included in sanctions list or terrorists list, or a person with a criminal background. If MLRO approves such High Risk client as the client of the Company, such client is subject to EDD which provides for thorough monitoring of all the client’s transactions. In this case, METASWAP applies the presumption that all the transactions of the client are suspicious unless the client proves otherwise.
Enhanced due diligence is required in circumstances giving rise to an overall higher risk.
Customers subject to EDD are required to provide additional documentary evidence and information.
As a result, the MLRO of METASWAP will take a decision to continue or terminate business relations with the respective client as well as to continue or terminate business relations with other clients who have the same beneficiaries or who conduct transactions on behalf of the same third persons.
Understanding the distinction between a customer's Source of Wealth and Source of Funds iscrucial for evaluating the legitimacy of their financial activities. METASWAP implements the following detailed procedures to assess these elements effectively:
Source of Wealth refers to the origin of the customer's overall wealth. This includes the various meansthrough which the customer has accumulated their wealth over time. Information Collection:
Employment: Gather details about the customer's employment history, including job titles, salary levels, and employers.
Business Activities: Collect information on any businesses the customer owns or is involvedin, including business type, financial performance, and ownership structure.
Investments: Obtain records of significant investments made by the customer, including realestate, stocks, bonds, and other assets.
Inheritance: If applicable, verify the source and amount of inherited wealth, including detailsof the estate or will.
Verification:
Consistency Check: Ensure that the reported Source of Wealth aligns with the customer's overall financial profile and declared income sources.
Documentation Review: Analyze provided documentation (e.g., employment contracts, business registration documents, investment portfolios) to validate the claimed Source of Wealth.
Source of Funds -pertains to the origin of the specific funds used in a particular transaction. It ensures that these funds are legitimate and consistent with the customer's Source of Wealth. Verification Procedures:
Transaction Analysis: Examine the details of individual transactions to determine the origin of the funds. This includes reviewing the source accounts and transaction history.
Supporting Documentation: Request and review relevant documents such as bank statements,financial records, and proof of transaction sources to verify the legitimacy of the funds.
Consistency Check:
Alignment with Wealth Profile: Confirm that the Source of Funds is consistent with thecustomer's declared Source of Wealth and business activities.
Transaction Patterns: Identify any unusual or inconsistent transaction patterns that may indicate discrepancies or potential red flags.
High-Risk Situations. Enhanced Due Diligence:
Additional Documentation: In cases deemed high-risk, request further documentation such astax returns, detailed bank statements, or comprehensive financial records to corroborate the Source of Funds and Source of Wealth.
Ongoing Monitoring: Continuously monitor the customer's transactions and financial activities for any discrepancies or unusual patterns that may arise.
Red Flags:
Inconsistencies: Look for inconsistencies between the Source of Wealth and Source of Funds,such as large transactions that cannot be explained by the customer's declared wealth.
Unusual Activity: Investigate any unusual or atypical transactions that deviate from the customer’s normal financial behavior.
METASWAP identifies certain jurisdictions as high-risk based on various factors, including weak Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) controls, high levels of corruption, or the imposition of international sanctions. To manage the risks associated with transactions or relationships involving these jurisdictions, METASWAP implements the following enhanced due diligence (EDD) measures:
Enhanced Scrutiny
Detailed Verification: All transactions involving high-risk jurisdictions undergo rigorous scrutiny. This includes thorough verification of:
Customer Identity: Confirm the identity of the customer through reliable and independent
sources.
Business Activities: Assess the legitimacy and nature of the customer’s business activities, including the origin and destination of funds.
Purpose of Transaction: Examine the purpose of the transaction to ensure it is consistent withthe customer’s known business profile and the nature of their operations.
Risk Assessment: Evaluate the specific risks associated with each transaction or customer relationship linked to high-risk jurisdictions. This includes analyzing factors such as the natureof the transaction, the customer’s risk profile, and the jurisdiction's AML/CFT environment.
Additional Documentation
Requirements: In transactions involving high-risk jurisdictions, METASWAP may request additional documentation to verify the legitimacy of the funds and the transaction itself. This documentation may include:
Detailed Financial Statements: Provide comprehensive financial records to substantiate the source of funds.
Proof of Transaction Origin: Include evidence of the origin of funds, such as bank statementsor transaction records.
Supporting Documentation: Submit additional documents that provide context and verification for the transaction, such as contracts, invoices, or correspondence.
Verification Procedures: Ensure that all additional documentation is reviewed carefully to confirm its authenticity and relevance to the transaction.
Ongoing Monitoring
Continuous Oversight: The Company conducts ongoing monitoring of customers and transactions associated with high-risk jurisdictions. This includes:
Transaction Monitoring: Regularly review transactions for any signs of suspicious activity ordeviations from normal behavior.
Customer Profile Updates: Continuously update and reassess customer profiles to reflect anychanges in their risk status or the risk environment of the high-risk jurisdiction.
Risk Mitigation: Implement measures to address any identified risks promptly. This may include adjusting the level of scrutiny, requesting further documentation, or taking other actions to mitigate risk.
Updating Risk Assessments
Regular Reviews: METASWAP maintains an updated list of high-risk jurisdictions based onguidance from international bodies such as the Financial Action Task Force (FATF). This listis reviewed and updated regularly to reflect changes in the risk landscape.
Procedural Updates: Regularly review and revise EDD procedures to ensure they align with the latest risk assessments and regulatory requirements.
METASWAP will use a combination of system alerts and blocks in order to facilitate effective transaction monitoring. METASWAP will regularly review the parameters to ensure they remain relevant. METASWAP will conduct ongoing monitoring of the business relationship which includes:
Monitoring is designed to identify unusual activity which may be indicative of money laundering or terrorist activity. Monitoring undertaken by METASWAP will:
After a corporate customer has been approved and brought on board, METASWAP performs a comprehensive process of transaction monitoring.
Key transaction monitoring data points include, but are not limited to:
When any employee either knows, suspects or has reasonable grounds for knowing or suspecting that a money laundering offence has been or is being committed they must make a suspicious activity report (SAR) to the MLRO.
If an employee becomes aware of, or suspect that, such offences are occurring during the course of their normal duties then they shall make a SAR to the MLRO.
METASWAP has made a SAR template available to the employees, all reports must be made using this template to ensure consistency. All reports must be fully documented and must include at a minimum the following information:
The fact that a report has been made and the content of the report must remain confidential at all times. The employee who forms or is aware of a suspicion of money laundering shall not discuss it with any outside party or any other member of staff unless directly involved in the matter causing suspicion.
No employee shall at any time disclose a money laundering suspicion to the person suspected. If circumstances arise that may cause difficulties with a client contact, the member of staff must seek and follow the instructions of the MLRO.
No copies or records of money laundering suspicion reports are to be made, except by the MLRO who will keep such records secure, and separate.
All the employees, anywhere within METASWAP, shall respond in full to all enquiries made by the MLRO for the purposes of evaluating a SAR. Information provided to the MLRO in response to such enquiries does not breach client confidentiality or professional privilege, and no member of staff shall withhold information on those grounds.
In some circumstances it may be necessary to obtain information from the customer before deciding whether or not to make a disclosure to the GIIF. In these cases the MLRO may request an appropriate person (such as a Fraud and Security, Marketing or Customer Services Supervisor) to make discreet enquiries of a customer. In such circumstances care will be taken to ensure that the offence of „tipping-off‟ will be avoided.
Under Section 7 of the Data Protection Act (DPA) a customer can request information regarding any of their personal information held or processed by an organisation – a Subject Access Request.
Section 29 of the DPA provides some exemption from responding to such a request when a SAR has been made, whether or not it has been reported to the GIIF.
Where a Subject Access Request is received and it is established that a SAR has been issued then the authority of the MLRO must be sought before any information relating to the SAR is released to the customer. The MLRO will keep a record of all such referrals. customer’s normal financial behavior.
The MLRO (or, if absent, the named deputy) shall receive and evaluate internal suspicion reports and decide whether a formal disclosure is to be made to the authorities. If so deciding, the MLRO will make the formal disclosure on behalf of METASWAP using the Suspicious Activity Report Form (see Appendix 14.2.).
Prior to making any such report the MLRO will undertake internal enquiries to satisfy themselves that, based on the information in the report and the result of their enquiries, they know or suspect, or have reasonable grounds to know or suspect, an offence of
money laundering. External reports will not be made until all available information has been considered by the MLRO, unless this would render such reports untimely. Such information includes:
Where the MLRO does not have immediate access to such information it will be provided as soon as is practicable by any relevant employee of the firm or any relevant employee of any organisation that provides outsourced services on behalf of METASWAP.
The decision whether or not there is knowledge, suspicion or reasonable grounds for knowledge or suspicion of a money laundering offence will rest with the MLRO or their delegated representative alone. Such a decision will not be subject to the consent of any other person within METASWAP.
From the moment a suspicion of money laundering arises, no further work will be carried out on the matter that gave rise to the suspicion. Neither commercial considerations nor the difficulty in responding to the clients enquiries on the matter shall be permitted to take precedence over METASWAP’s legal obligations in this regard.
The GIIF has up to seven (7) days to confirm whether or not the transaction, for which a consent has been requested, can proceed – until the GIIF gives consent, the transaction cannot proceed – it is frozen. In these circumstances, the staff member must be very careful that they do not „tip off‟ the customer about the reason for the delay in processing the transaction.
Where the GIIF gives notice that consent to a transaction is refused, a further thirty one
(31) day period (the “Moratorium”) commences on the day that notice is given. The thirty one (31) days include Saturdays, Sundays and public holidays. It is an offence to undertake the transaction during this period as the participant would not have the appropriate consent. If the Moratorium period expires and no such action has been taken, the reporter is free to proceed with the act(s) detailed in the initial disclosure.
It is METASWAP policy that all requests for consent must be processed through the MLRO – it is expressly forbidden for employees to make a „consent‟ request direct to the GIIF.
This Policy is effective on METASWAP’s wide basis from the date of its publication.
Its contents will be reviewed periodically, and any changes or modifications will be made as appropriate.
VERSION CONTROL TABLE
Version
Approval date
Changes description
Director’s signature confirming
approval
MLRO’s
signature confirming approval
1.0
25.05.2025
First issue
Denys Makhno
Denys Makhno
ANNEXES
COMPANY BASIC INFORMATION
Company name:
Registration number:
Date of Formation:
Registered Company Address (Street, House Number, Postcode/ Zip Code, City,
Country):
Address of Business (if different from Registered Company Address):
TIN (number, country):
Website:
Telephone:
Email:
Industry:
Goods and Services:
Describe in detail the business
processes of the company:
Describe the purposes for which you
plan to use the services of METASWAP:
Names of the director, members of the management board, or other body
replacing the management board, and their authorization in representing the
legal person:
BUSINESS DESCRIPTION
Business structure of the company:
Business description:
In which countries Business is run?
Describe the primary focus of the
Business’s business line:
Top 5 business partners and jurisdictions in which they reside:
Annual turnover:
DIRECTOR
First Name:
Last Name:
Passport/ID number:
Date of Issue:
Date of Expiration:
Nationality (Citizenship):
Adress of residence:
Date of Birth:
Place of Birth:
Sex
Male/Female
PEP
YES / NO
Tax Residency (country, tax number):
SHAREHOLDER-LEGAL ENTITY
Legal Name of the entity:
Incorporation Date:
Registration Number:
TAX Identification No:
Registered Company Address
(Street, House Number, Postcode/ Zip Code, City, Country):
Place of business (if different from
Registered Company Address):
Director (name, surname, ID):
SHAREHOLDER-NATURAL PERSON
First Name:
Last Name:
Passport/ID number:
Date of Issue:
Date of Expiration:
Nationality (Citizenship):
Adress of residence:
Date of Birth:
Place of Birth:
Sex
Male/Female
PEP
YES / NO
Tax Residency (country, tax number):
BENEFICIAL OWNER
First Name:
Last Name:
Passport/ID number:
Date of Issue:
Date of Expiration:
Nationality (Citizenship):
Adress of residence:
Date of Birth:
Place of Birth:
Sex
Male/Female
PEP
YES / NO
Tax Residency (country, tax number):
SOURCE OF FUNDS
Please specify the source of funds
Name:
Signature:
Title:
Date:
LIST OF REQUIRED DOCUMENTS
Please provide all available company documents as listed below. Once approved we will finalize your application.
№
Type of document
1.
Proof of ID (International passport, EU ID card)
2.
Selfie with the Document
3.
Proof of Address
Beneficial Owner (UBO) ONLY, repeat steps above and include:
4.
Current CV (containing experience, education, occupation)
5.
Source of wealth and funds
6.
Certificate of incorporation
7.
Memorandum of Association
8.
Articles of Association
9.
Certificate of Shareholders
10.
Certificate of Registered address
11.
Reference letter from the bank confirming company bank account details
12.
List of directors
This document describes list of information shall be obtained when METASWAP applies CDD measures and criteria for information requested. This list is non-exhaustive and sets minimal requirements for information collected. Additional information may be requested by the decision of METASWAP’s employee, if it´s necessary for adequate performing of CDD measures.
Please note! All the information should be filled out in English language as well as provided documents.
KYC QUESTIONNAIRE
Full name:
Date of birth:
Residential Address:
Nationality:
Passport / ID number:
Date of Issue:
Date of Expiration:
Country of issue of Passport / ID number:
Email:
Phone number:
Purpose of the business relationship:
Source of Wealth declaration:
Verification if the Customer is a PEP, their family member or close associate: YES/NO
Name:
Signature:
Date:
LIST OF REQUIRED DOCUMENTS
Please provide all available documents as listed below. Once approved we will finalize your application.
№
Type of document
1.
Proof of ID (International passport, EU ID card)
2.
Selfie with the Document
3.
TIN (tax identification number)
4.
Proof of Address
5.
Source of wealth / Funds declaration
PROOF OF SOURCE OF WEALTH AND FUNDS
Source of Wealth (SoW)
SoW refers to the origin of the customer’s entire body of wealth (i.e., total assets). SoW explains the activities the customer participates in and their geographical location. This information will usually indicate as to the volume of wealth the customer could be expected to have, and a picture of how the customer acquired such wealth.
Examples of SoW: ownership of business, employment, inheritance, investments.
Source of Funds (SoF)
SoF refers to the origin of funds being deposited, received, or transferred with the financial institution. SoF tells where the money is coming from, which can be proven through bank statements, tax returns etc.
Examples of SoW and SoF and supporting documentation required:
Income category
Documents required
Income from salary
account
Inheritance
statement showing these funds being deposited into the account
statement showing these funds being deposited
into the account
Gift/Donation
statement showing these funds being deposited into the account
Scholarship
statement showing these funds being deposited into the account
Savings/deposits
Divorce Settlement
regulated status and a bank statement showing these funds being deposited into the account
Government grants (retirement income, grants for veterans, research grants, etc.)
The company profit/dividends
Sales (of property, goods, shares etc.)
bank statement showing these funds being deposited into the account
Loan or investment
confirming the agreement and a bank statement showing these funds being deposited into the
account
Prohibited and very high-risk countries list
Afghanistan
Prohibited
Bahamas
Prohibited
Barbados
Prohibited
Belarus
Prohibited
Botswana
Prohibited
Burundi
Prohibited
Cambodia
Prohibited
Cayman Islands
Prohibited
Central African Rep
Prohibited
Comoros
Prohibited
Congo, the Democratic Republic
Prohibited
Cuba
Prohibited
El Salvador
Prohibited
Eritrea
Prohibited
Gaza Strip
Prohibited
Guinea Bissau
Prohibited
Haiti
Prohibited
Iran, Islamic Republic of
Prohibited
Iraq
Prohibited
Jamaica
Prohibited
Jordan
Prohibited
Lao People's Democratic Republic
Prohibited
Lebanon
Prohibited
Libya
Prohibited
Mali
Prohibited
Mongolia
Prohibited
Morocco
Prohibited
Mozambique
Prohibited
Myanmar
Prohibited
Nicaragua
Prohibited
North Korea
Prohibited
Pakistan
Prohibited
Panama
Prohibited
Russian Federation
Prohibited
Senegal
Prohibited
Somalia
Prohibited
South Sudan
Prohibited
Sudan
Prohibited
Syria
Prohibited
Trinidad & Tobago
Prohibited
Turkmenistan
Prohibited
Uganda
Prohibited
Ukrainian territories of Crimea, Donetsk, Luhansk, Sevastopol, Zaporizhzhia and Kherson
Prohibited
Uzbekistan
Prohibited
Vanuatu
Prohibited
Venezuela
Prohibited
West Bank (Palestinian Territory)
Prohibited
Western Sahara
Prohibited
Yemen
Prohibited
Zimbabwe
Prohibited
Albania
Very High
Algeria
Very High
Angola
Very High
Belize
Very High
Benin
Very High
Bolivia
Very High
Burkina Faso
Very High
China
Very High
Cote D'Ivoire
Very High
Kenya
Very High
Kyrgyzstan
Very High
Madagascar
Very High
Mauritania
Very High
Nigeria
Very High
Philippines
Very High
Sierra Leone
Very High
Sint Maarten
Very High
Tajikistan
Very High
Turkey
Very High
Vietnam
Very High
METASWAP must ensure that sanctions screening is performed according to the company mandatory lists: EU, UN and US Department of Treasury - Office of Foreign Assets Control (“OFAC”)
EU
https://www.sanctionsmap.eu/#/main OFAC
https://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx United Nations
United Nations Security Council Consolidated List | United Nations Security Council
To: Money Laundering Reporting Officer
From (name of employee)
Date:
This SAR is (circle which applies):
I consider the following transaction suspicious and report to you under the internal reporting procedure:
Signature of reporting staff
Private and Confidential
From: Money Laundering Reporting Officer Transaction number:
Customer:
Amount:
Internal SAR received from:
Date SAR received:
I confirm that I have reviewed the internal SAR and customer ID for this customer plus transaction history (all documents attached)
I confirm that, based on the information received and reviewed, I have:
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