AML Policy
ALP Labs Sp. z o.o. (“Alppay” / “Company“) has no tolerance for money laundering, the financing of terrorism, or any other form of illicit activity. The Company is committed to implementing policies, procedures, and controls based on the best industry practices and the most effective anti-money laundering standards applied in Poland and worldwide.
Purpose
This document provides the Company’s partners, clients, vendors, contractors, employees, regulators, law enforcement, and other stakeholders with a high-level overview of the Company’s AML/CTF compliance elements and procedures. This document should not be viewed as an exhaustive set of policies but as an overview.
Regulatory Compliance
Alppay is required to comply with the Money Laundering and Terrorist Financing Prevention Act and the International Sanctions Act. These regulations mandate client identity verification, transaction monitoring, record-keeping for five years, and reporting certain transactions.
Money Laundering Definition
The Company defines money laundering as:
- Conversion or transfer of property derived from criminal activity, aimed at concealing its illicit origin.
- Concealment of the nature, source, or ownership of property derived from criminal activity.
- Acquisition or use of property known to be derived from criminal activity.
- Participation or aiding in any actions related to points above.
Terrorist Financing
Terrorist financing provides funds for terrorist activities with the objective to intimidate a population or compel a government to act. It includes various forms of serious harm or disruption.
Risk-Based Approach and Risk Assessment
Alppay performs a risk-based due diligence assessment of each client to determine a risk profile. The risk assessment considers factors like customer risk, geographical risk, product risk, and delivery channel risk.
Compliance Officer Duties
- Collection and analysis of information on suspicious transactions
- Reporting to Polish Financial Supervision Authority (KNF) for suspicious activity
- Regular compliance reporting to management
Procedures and Controls
Alppay has implemented procedures for due diligence, risk management, data retention, and sanctions screening. Employees are required to strictly adhere to these procedures.
Due Diligence
The Company applies:
- Simplified due diligence for lower-risk clients.
- Enhanced due diligence for higher-risk clients, such as PEPs or clients from high-risk countries.
Politically Exposed Persons (PEP)
Enhanced scrutiny is applied to Politically Exposed Persons (PEPs) and their close associates to prevent misuse of financial systems.
Sanctions Screening
The Company screens clients against UN, EU, OFSI (UK), and OFAC (US) sanctions lists, escalating true matches to the Compliance Officer.
Suspicious Activity Monitoring and Reporting
Alppay reports suspicious activity to the KNF within two business days. Employees are prohibited from informing clients about these reports.
Data Retention
The Company retains identification and verification data for at least five years post-business relationship termination, using it solely for AML/CTF purposes.
Training
The Compliance Officer ensures that employees are trained on AML/CTF obligations. Training frequency is based on regulatory changes and business needs.
Cooperation and Information Exchange
Alppay cooperates with regulatory and law enforcement bodies to prevent money laundering and terrorist financing. External requests should be directed to [email protected].
KYC Policy
The KYC Policy includes:
- Verification Procedures
- Monitoring Transactions
- Risk Assessment
1. Verification Procedures
Alppay’s verification procedure requires Users to submit reliable documents, such as IDs and utility bills.
2. Monitoring Transactions
Alppay monitors transactions to detect unusual patterns and reserves the right to take action on suspicious transactions.
3. Risk Assessment
Alppay adopts a risk-based approach to prioritize resources and manage AML/CTF risks effectively.