Anti-Money Laundering Policy

Updated June 10th, 2021

I. What is money laundering? Types of money laundering

1. What is money laundering?

Money laundering is an act of an organization or individual in order to legalize the origin of the proceeds of crime, including:

a) Acts of money laundering:

  • a.1 Participating directly or indirectly in financial, banking or other transactions in order to conceal the illegal origin of money or property due to their crimes, but having or knowing or having grounds to know is committed by others.
  • a.2 Using money or property that they have committed a crime with, or knowing or having grounds to know, that someone else has committed a criminal act, to conduct business or other activities.
  • a.3 Concealing information about the origin, true nature, location, movement or ownership of money or property due to the crime that is or knows or has grounds to know is due to another person. other offenders that obtain or impede the verification of such information.

b) Assist organizations and individuals involved in crimes to evade legal responsibility by legalizing the origin of property obtained from crime.

c) Possessing property if at the time of receiving the property, it is known that such property was obtained by committing a crime, in order to legalize the origin of the property.

2. Types of money laundering

The purpose of money laundering is to create the furthest distance between illegal assets and the owners of those assets. The initial form of expression of profit is usually "money", but after the transition to legalize "money", there are other forms of expression such as checks, credit cards, real estate. product...

  • Money laundering through direct cash transactions
  • Laundering money through buying gold, silver, diamonds
  • Money laundering through investment in savings, buying bills, bonds
  • Money laundering through the “underground” banking system...

II. MEASURES TO PREVENT MONEY LAUNDERING

1. Customer identification policy:

1.1. For individual customers:

- Full collection: ID card or passport, address, phone number, occupation.

- Collect a full bank account number.

1.2. For customers who are organizations:

Full transaction name and abbreviation; head office address; phone number; fax number; date of establishment license/registration; establishment agency; business activities; information about the legal representative of the organization.

1.3. Strengthen requirements on collecting and managing customer information when necessary:

- Collect bank statements

- Electricity bill

- Direct phone calls to verify customer information...

And all other lawful methods of double-checking identifying information will be used and ONUS reserves the right to investigate certain Users that have been identified as risky or suspicious. ONUS reserves the right to verify a User's identity on an ongoing basis, especially when their identity has been changed or their activity appears suspicious (unusual for a particular User). In addition, ONUS reserves the right to request updated documents from Users, even if they have passed identity verification in the past.

User's identifying information will be collected, stored, shared and strictly protected in accordance with ONUS's Privacy Policy and related regulations.

2. Screening, detection and handling measures:

2.1. ONUS collects and lists the list of suspects and the list provided by the competent authority.

- Screening from the very beginning when users sign up.

- Focus on information integrity and effectively identify customers.

- Statistics, setting up the customer rating mechanism.

2.2 Control, recognize from transactions

- Enhanced analysis and monitoring of reports of suspicious transactions

- The specialized department must review, screen and identify customers for large-value transactions to detect suspicious transactions, or transactions related to money laundering.

- Report suspicious transactions

- Enhanced analysis and monitoring of reports of suspicious transactions

- Improved AML data analysis and monitoring standards

- Check for unusual changes in transactions:

  • Transactions are made continuously
  • Trades with a large volume and with a difference
  • New customers, occasional transactions
  • Money is moved around through many different wallet accounts, the parties involved do not care about transaction fees
  • Transactions are made under orders or authorizations of individuals and organizations involved in criminal activities on the list of statistics and warnings set up by the competent legal authority to prevent , fight against money laundering
  • The transaction is conducted by a customer related to illegal activities that have been published in the mass media or included in the warning list provided by the competent legal authorities

2.3 Detecting and handling:

- The handling of suspicious transaction reports on the basis of analysis and information processing throughout the system; How to communicate with customers who make suspicious transactions to ensure non-disclosure of information.

- Daily check with verified blacklist, watchlist or denial of service.

- Develop procedures for information storage and security, specifying methods of storage and exploitation; retention level.

- Application of provisional measures, handling principles in cases of delay in transaction performance: provide specific cases of application of temporary measures; specifying responsibilities at all levels to apply, approve the implementation of requirements of functional agencies.

- Locking, terminating a user account when ONUS reasonably suspects that such User is engaged in illegal activity.

- Develop a reporting regime, provide information to relevant departments and competent agencies to receive AML reports.

3. Control Department & Legal Department and Anti-Money Laundering:

- The Control Department & Legal Department (or staff) are duly authorized by ONUS, responsible for ensuring the effective implementation of AML/KYC policy in conjunction with relevant departments to effectively enforce.

Responsible for overseeing all of the above measures and aspects of anti-money laundering activities, including but not limited to:

  • Collect customer identification information.
  • Establish and update internal policies and procedures for the completion, review, submission, and retention of all reports and records required by applicable laws and regulations.
  • Monitor transactions and investigate any significant deviations from normal operations.
  • Implement a records management system to store and retrieve appropriate documents, files, forms, and logs.
  • Update risk assessment regularly.
  • Provide information to law enforcement as required by applicable laws and regulations.

Legal BP & Controllers reserves the right to interact with law enforcement, in relation to the prevention of money laundering, terrorist financing and other illegal activities.