Anti-Money Laundering/Terrorist Financing Policy for LA Circum

Preamble

Financial services institutions recognize money laundering and terrorist financing as major global threats. As part of our commitment to compliance, lacircum is implementing a comprehensive AML/CFT policy. This policy aims to comply with the rules of European Union countries, Irish and European legislation, as well as the provisions of the FATF, the United Nations and OFAC. It represents the minimum standards to be adopted and respected.

Aim of our policy

The aim of this policy is to combat money laundering, terrorist financing and tax fraud, and to protect the community. We implement strict KYC (Know Your Customer) standards for customer intake, identification, verification, customer risk assessment, transaction screening, monitoring, suspicious transaction reporting, and termination or refusal of business relationships. We also provide training and awareness-raising for our teams to implement these actions.

Objectives

Our objectives are as follows:

Prevent the use of lacircum for money laundering, terrorist financing and tax fraud.
Prevent any association of Circum with money laundering or terrorist financing activities.
Comply with AML/CFT laws and regulations wherever lacircum operates.

Measures

We implement the following measures:

A policy of identity verification (KYC) requiring the submission of valid identification, selfies of the user with their ID, and verification of bank accounts used for SEPA transactions.

Strict verification of payment cards used, including sending a photo of the card showing the last 4 digits and the owner's name.

Matching of telephone lines and IP addresses with declared places of residence and nationalities.

The right to refuse any person or entity presenting inconsistencies or risks.

The possibility of terminating business collaboration in the event of fraudulent or risky activity.

Automatic reporting to local authorities in the event of serious suspicions of money laundering, tax fraud or terrorist financing.

Cooperation with the authorities in the event of proven fraud or a request for information.

Conclusion

This LBC-FT policy forms an integral part of our general terms and conditions of use. Users are required to read and accept them before using lacircum services.