Avencia Digital Ltd. (“Avencia Digital” or “the Firm”) conducts its activity according to the provisions and requirements of its Anti-Money Laundering and Counter Terrorist Financing Policy (“the Policy”) and adheres to the highest Anti-Money Laundering and Counter Terrorist Financing standards including but not limited to 40 Recommendations of the Financial Action Task Force (FATF), the EU’s 4th and 5th Anti-Money Laundering Directive, and UK’s Money Laundering Regulations.

The main elements and requirements of Avencia Digital’s Policy are as follows:

  • identifying and verifying the identity of its customers in compliance with Avencia Digital’s Know Your Customer Policy and Procedure (“the KYC Policy”);
  • assessment of the money laundering risks and taking risk-mitigating measures;
  • Know Your Customer, customer acceptance and risk-sensitive due diligence measures in compliance with Avencia Digital’s KYC Policy;
  • risk-sensitive customer approval for a business relationship inception or continuation of an existing business relationship; and
  • ongoing monitoring of customers, their activities, and transactions, including cryptocurrency tracing employing dedicated systems, controls, and Chainalysis tool to detect significant, complex, unusual and suspicious transactions and patterns to prevent the use of Avencia Digital for money laundering or terrorist financing purposes.

It is the Policy of Avencia Digital not to open anonymous accounts and not provide its services to customers who are not duly identified and their identity verified. The Firm applies restrictive measures in regard to funds and crypto assets, which are originated, belong to, owned, or controlled, directly or indirectly, by designated individuals, group of people or legal entities according to lists of international or country-specific sanctions according to the programs administered by specialised agencies and bodies of the UN, US, EU, and the UK.

For the purpose described above, Avencia Digital conducts screening of customers and their transactions during onboarding new customers and the process of trade execution, including at regular intervals. The screening is part of the Firm’s due diligence measures and informs the Firm’s risk assessment of customers. The screening is conducted against sanction lists of designated individuals and entities, Politically Exposed Persons, crimes and criminal records, enforcement, and adverse media. The screening employs the use of a dedicated screening tool Northrow Contigo.

The Firm has a risk-based approach in conducting transactions and monitoring of customers’ transactions and activities with due consideration to various risk factors, including jurisdictional risk, customer risk, and nature of the business activity. Although Avencia Digital provides its services to UK and EEA domiciled customers only, it has due consideration to those countries which fall under the countrywide and comprehensive sanctions and embargos or those jurisdictions which pose a significant risk. Avencia Digital reserves the right to terminate a business relationship unilaterally or reject certain transactions with those customers of whose transactions or activity poses a prohibited or significant risk for the Firm.

In conducting the monitoring of customers’ transactions and activities, the Firm uses advanced technology and monitoring solutions provided by leading vendors Chainalysis and ComplyAdvantage, which permits monitoring the cryptocurrency on the Blockchain, flagging patterns of unusual activity and generating alerts. The alerts are generated by both systems Chainalysis and ComplyAdvantage for both transaction types: wallet transfers on the Blockchain and payment transactions between bank accounts. In addition, as part of transactions monitoring, the Firm deployed specific controls to limit and control the risk of money laundering and better understand the customers’ activity, the origin and use of funds.

Avencia Digital keeps all documents and information about its customers for as long as required, for the whole period of a business relationship and a minimum of five years following the termination of a business relationship.

The personal data is processed in line with Avencia Digital’s Privacy Policy and applicable laws. The customer’s access to and use of the Firm’s products and services is conditioned on the customer’s acceptance of the Privacy Policy. Avencia Digital’s Privacy Policy describes the Firm’s policies and procedures on collecting, using, and disclosing customer’s personal information when the customer uses Avencia Digital’s services and informs the customer about privacy rights and how the law protects the customer in its capacity of the data subject. Therefore, the customer shall read Avencia Digital’s Privacy Policy carefully before using the Firm’s products and services.

Under the Money Laundering Regulations, the Firm has appointed a Nominated Officer, of whose name is communicated to the Financial Conduct Authority (“the FCA”). The name of the Nominated Officer is Sergiu Sagaidac, a certified anti-money laundering, risk & compliance professional and holder of multiple credentials including but not limited to CAMS-RM, AICA Adv.Cert(Comp), PIOR awarded by the Association of Certified Anti-Money Laundering Professionals (ACAMS), International Compliance Association (ICA) in partnership with the Manchester Business School, and the Institute of Operational Risk (IOR) in collaboration with the Institute of Risk Management (IRM). Sergiu also is a graduate of Free International University and holder of an MSc degree in Banking and Finance. In addition, he completed the Blockchain Strategy Programme of the Said Business School of Oxford University and is a holder of the qualification awarded by this academic institution.

The Nominated Officer’s responsibilities are as follows: -

  • Receive internal suspicious activity reports (“SARs”) of related knowledge or suspicions of money laundering / terrorist financing;
  • Investigate reports of suspicious events;
  • Investigate reports of unusual activity and patterns of unusual transactions;
  • If required, submit a SAR of suspicious activity to the National Crime Agency (“the NCA”);
  • Ensure the adequacy of arrangements made for the anti-money laundering/counter terrorist financing awareness and training of staff, advisers and the Board of Avencia Digital;
  • Report to the Board (at least annually) on the operation and effectiveness of the Firm’s Anti-Money Laundering and Counter Terrorist Financing systems and controls;
  • Monitor the day-to-day operation of anti-money laundering policies in relation to the development of new products; the taking on of new customers; and changes in the Firm’s business profile;
  • Ensure 5th Anti-Money Laundering Directive reporting obligations to the Financial Conduct Authority are undertaken in a timely and complete manner; and
  • Monitor compliance-related issues.

Sergiu Sagaidac is a member of the senior management staff and the Board of Directors. As a Nominated Person, he reports directly to the Chairman of the Board of Directors and acts independently as the Firm’s Money Laundering Reporting Officer and Head of Compliance. He can be contacted via email at sergiu.sagaidac@avencia.digital.

It is the Policy of Avencia Digital that all members of staff shall pass the employment screening and actively participate in preventing the services of Avencia Digital from being exploited by criminals and terrorists. This participation has as its objectives:

  • ensuring Avencia Digital’s compliance with applicable laws, statutory instruments of regulation, and requirements of the FCA;
  • protecting Avencia Digital and all its staff as individuals from the risks associated with breaches of the law, regulations, and supervisory requirements;
  • preserving Avencia Digital’s good name against the risk of reputational damage presented by implication of involvement with money laundering and terrorist financing activities; and
  • making a positive contribution to the fight against crime and terrorism.

To achieve these objectives, it is Avencia Digital’s Policy that:

  • every member of staff shall meet their personal obligations in accordance with their role, responsibilities, and position in Avencia Digital;
  • commercial considerations shall never be permitted to take precedence over Avencia Digital’s anti-money laundering commitment; and
  • Avencia Digital’s Nominated Person is given every assistance and cooperation by all members of staff in carrying out the duties of the appointment.

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