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:
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.
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: -
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 firstname.lastname@example.org.
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:
To achieve these objectives, it is Avencia Digital’s Policy that: