Principles for the implementation of internal regulation to prevent money laundering and sponsorship of terrorism

The WillowsUnion Services website operates in accordance with the present law of the Estonian state and respectfully accepts the laws of other states whose users can go to this site and use these services in accordance with the established Principles. There is a possibility that virtual money can be used in fraudulent activities, including the laundering of profits obtained through fraud and/or sponsorship of banditry. To prevent such operations using the services of the site and other similar illegal activities, we are obliged to secure honest users and their money.

To achieve this goal, we have developed this AML Program, the Service Principles and other documentation and provisions describing the rules for the functioning of the WillowsUnion service. This program is strictly followed by our employees, which reduces all the dangers associated with the operation of the Services to a minimum.

The resources available to the Service enable us to identify risky trades and/or transactions associated with the exchange and to carry out verification on them. Details of the work and mechanisms of operation of the Service are not disclosed in order to ensure the safety and productivity of its functioning in the field of combating illegal activities. The Service has all the powers to require at various stages from each User the implementation of an identifying procedure and / or presentation of various data / documents that are of interest to the Service and that can be useful in proving the legality of the origin of funds and confirming the identity of the User.

Please be advised that the WillowsUnion service can verify identity (KYC) and/or guarantee compliance with the AML program, either through its own funds or through the involvement of other companies and services.

 

1. General principles

1.1 The existing AML program is created in accordance with the current law of the Republic of Estonia.

1.2 Service - an Internet resource for converting cryptocurrency - WillowsUnion - the site https://WillowsUnion.com and related add-ons (including mobile ones) located on the worldwide network.

1.3 The User is a citizen who has reached the age of sixteen, or the period of majority established by the authorization applied to the User. In case of non-compliance with the clause relating to the age limit, the user is obliged to immediately stop using the Service and exit the resource / close the add-on.

1.4 The AML Program is a set of internal principles (these principles) and rules developed and applied by the WillowsUnion service in order to verify and provide access to documents and data on transactions that are under control without fail. Also, these are other financial and / or property transactions that have any relation to money laundering (legalization) and / or sponsorship of banditry and the submission of such information to public authorities.

In order to ensure the legality and transparency of monetary transactions through the WillowsUnion service, these principles are applied to prevent criminal activity, including the prevention of money laundering, when committing fraudulent transactions using the functionality of the Service. These principles are relevant for all users of the WillowsUnion Service who carry out any transactions related to various forms of financial flow through the Service.

1.5 An AML program is an act that:

1.5.1 Controls the organizational process to prevent money laundering (legalization) obtained by criminal means and sponsorship of banditry;

1.5.2 Defines the responsibility and necessary operations for employees to implement internal regulation;

1.5.3 Determines the time during which employees perform their duties and determines the persons who have the right to control.

1.6 The AML program includes support programs;

1.6.1 A program to consider different ways of implementing internal regulation;

1.6.2 The program of inclusion of methods of internal regulation;

1.6.3 The visitor and individuals associated with the program identifying the visitor;

1.6.4 Hazard Research Program;

1.6.5 Program for the settlement of economic relations with visitors;

1.6.6 Necessary measures of the program regulation in case of fear of procedures related to laundering of proceeds obtained illegally;

1.6.7 Program of mutual exchange of correspondence;

1.6.8 Program for recording documentary data;

1.6.9 Operation rejection program;

1.6.10 Professional development program for employees of the Service;

1.6.11 Internal regulation implementation program;

1.6.12 The program for organizing the workflow related to documents received in the process of implementing the internal regulation program.

1.7 This WillowsUnion Service Manager is the person responsible for the smooth execution of this program.

 

2. Organizational forms of regulation methods

2.1 For the appropriate conduct of this program and taking into account the number of visitors and the resulting hazard levels, the Service management has organized a separate group, including managers, an accountant and a security manager, to implement the AML program.

2.2 Certain employees of the Service deal with all tasks related to the initial recognition of the visitor.

2.3 Clause 1.7 of this program determines the person responsible for resolving the following issues:

• study of a transaction made or planned for carrying out for its potential involvement in money laundering, or sponsoring banditry;
• providing the Financial Inspectorate with various information about visitors, related persons and transactions that potentially relate to criminal activity;
• provision of reporting documentation on the implementation of this program;
• implementation of other obligations determined by the Agency for Combating Money Laundering and Sponsoring Banditry.

 

3. Introduction of regulation methods

3.1 Regulatory methods are applied in the following situations and areas:

• at the time of establishing economic relations with the User and in the course of his work;

• in all cases when the transaction amount is more than 15,000 euros, or is equivalent to this value in any monetary unit;

• in case of uncertainty about the correctness and / or veracity of the information provided;

• in case of extreme complexity of the planned operation;

• if there are suspicions that the transaction is involved in money laundering and/or sponsorship of banditry, and/or other type of illegal activity and/or refers to transactions with a high degree of danger according to the risk assessment procedure adopted by this program.

In case of detection of a potential connection with such companies as: Darknet Marketplace, Darknet Service, Fraudulent Exchange, Illegal Service, Mixing Service, Ransom, Scam, Stolen Coins, in the process of automated AML monitoring of the User"s e-wallet address. Upon confirmation of such relations, the return of funds to the sender"s address will occur only after the identification of the User (the amount is subject to return, taking into account the commission taken for the operation).

3.2 Additional methods of regulation are applied when the User changes the rules and / or subtleties of the exchange, and / or incomplete implementation and / or non-implementation of them, increasing the degree of danger:

• in the case when the exchange is not appropriate (does not contribute to a meaningful task);

• in case of economic irrationality;

• in the case of repeated repetition of the same type of operation in a short period of time;

• in the event that the User does not provide the data requested by the Service, in the situations and sequence specified in this program and / or the Principles of the Service, without explaining the grounds for refusal and / or in cases where the User expresses extreme concern about secrecy tasks;

• in the event that the User decides to change the transaction by a method that is not typical in the practice of conducting exchange transactions;

• if the User hastened to complete transactions/exchange/operation without any reason;

• in the event that the User makes changes to the rules of the operation/exchange immediately before its/his implementation;

• in case of impossibility to connect with the User at the specified e-mail address and/or telephone number and/or other contact data;

• in the event of the appearance of data and / or assumptions about the untruthfulness and / or incorrectness of the information provided by the User;

• in case of extreme complexity of the planned operation/exchange and lack of evidence of the financial reason.

3.3 Auxiliary methods of regulation of doubtful transactions:

• acceptance of mandatory clarifications and evidence from the client explaining the subject of the operation/exchange;

• implementation of intensive monitoring in accordance with these principles regarding all transactions of the visitor to confirm any connection with money laundering and / or sponsorship of banditry.

 

4. Verification program for visitors and related personalities

4.1 Primary verification of the visitor is carried out on the basis of the information provided by the visitor and / or documentation confirming the identity.

4.1.1 Identification of the User is carried out using the software of the partner service specified in the Service Regulations and in accordance with them, as well as the Principles of Secrecy.

4.1.2 Individuals require confirmation of the following information:

• name;

• surnames;

• patronymic (if any);

• nationality;

• date of birth, own identification code;

• passport data;

• place of residence;

• own tax number (TIN), if any;

• place of work of the User (occupation);

• contact information - telephone number, e-mail address.

4.1.3 During the verification process, documentary information is analyzed to confirm its veracity and the following is proved:

• the truth of the document;

• the authenticity of the photograph on it;

• compliance of the personal identification number of a person with his gender and the number of years;

• suspicions about the authenticity of the document. It is possible to conduct an audit through communication channels with the state apparatus that issued the document and accept important data and / or evidence.

4.1.4 If a visitor provides a passport, a high-quality duplicate is created, which makes it possible to see the information contained in it.

4.1.5 In the process of verification of an individual, information regarding the person"s affiliation with civil servants is investigated and proved;

a public official is a citizen holding a government rank in any state of the EU (European Union) and / or any other state, or a citizen holding a position in an intergovernmental company. In case of proof of belonging of an individual to public servants:

• there is a collection of information from the place of his work;

• a list of closest colleagues and relatives, if the data is available to the public;

• proof of the property and origin of income that is planned to be used in the operation/exchange;

• submission of a request to the required information storage;

• submitting a request to the state supervision center;

• make a choice in favor of starting market relations with a civil servant by making a choice by established officials in accordance with paragraph 2.1 of this program.

4.1.5.1 In order to confirm the information provided, only government documents, namely state lists and / or representations of foreign states, can be used. It is possible to use other resources in case of evidence of their correctness and

4.1.6 Only official sources, such as state registries and/or foreign representations, can be used to verify the information provided. Other sources may be used if there is no doubt about their accuracy and evidence.

4.1.7 Guidance to a trusted visitor will not replace a thorough analysis of the data.

4.1.8 The verification process of an authorized individual is carried out in accordance with the rules of this program, the Service Principles and the Face Verification Program.

4.1.9 The process of verification of an individual is not a one-time procedure. It is obligatory to check and update data on an individual.

4.2 All documentation issued by the government authorities of another country must be authentic or have an apostille, excluding documents from the Latvian, Lithuanian, Polish, Russian or Ukrainian states. These rules may change if the Estonian state signs and ratifies an intergovernmental agreement with a different interpretation, in which case the apostille will lose its relevance.

4.3 In the event of a low risk of a transaction, or if there are reasons for suggesting a low degree of risk of economic ties, a unified method of regulating visitor verification may be applied. Verification of information can be carried out through information repositories that can be accepted as reliable. In addition to the low degree of hazard determined during the risk study process, additional factors that consider the operation as low risk may be:

an individual living in the Estonian state or another state that has a strong anti-money laundering system at the state level.

The use of a unified way of managing does not relieve the organization of the obligation to ensure the transparency of the operation.

4.4 In the case of a high degree of danger or there are reasons for investigating a high level of risk of financial relationships, a higher degree of regulation of visitor verification should be used.

This can be done by asking the visitor for supporting data and documents that help reduce our risk. The data must be presented to the Estonian Financial Inspectorate for further instructions. In addition to the high degree of risk indicated in the risk study process noted above, the supporting factors to consider an operation as a high risk are the following:

• special conditions of operations;

• the visitor uses a large amount of cash;

• the essence of the operation is new or unknown goods and unusual features of the operation;

• the operation is carried out for the purpose of secrecy;

• unknown outsiders make payments after the operation;

• other situations referred to in Article 37 of the Estonian Money Laundering Regulations and the Regulations on Prevention of Sponsoring Banditry.

4.5 The use of a high-ranking regulation method can only be excluded with the permission of the Estonian Money Laundering Prevention Department.

4.6 A transaction with a high degree of risk cannot be carried out without the prior permission of the Estonian Money Laundering Prevention Department.

 

5. Hazard assessment

5.1 Each Visitor and his planned operation can be assessed in terms of economic risk in the field of money laundering and sponsorship of banditry (user risk).

5.1.1 During the hazard assessment process, the User is assigned a hazard status from low to the highest.

5.1.2 Methods for assessing subsidiary causes of hazard:

• whether the User belongs to a government official or is related to him;

• in the event that the recipient of the benefit / addressee of the exchange of the physical entity is an outsider;

• in case of failures during verification;

• The user is related to low-tax jurisdictions;

• Application of intergovernmental sanctions to the User;

• there is a positive experience of interaction with the User;

• period of time of interaction / date of initial registration of the profile;

• type of planned operation;

• transaction amount;

• The user is permanent and/or stably exchanges;

• the sources of goods and/or capital are unknown.

5.2 The type of operation needs to be assessed to determine the degree of hazard.

5.2.1 An exchange operation can be assigned a level of low, medium and high danger, depending on the following reasons:

• a commercial bank takes part in the exchange;

• the operation provides for other payment methods;

• the exchange is related to gambling;

5.3 Assessment of geographical factors (geographical hazard).

5.3.1 A transaction may be assigned a low, medium or high risk status depending on the following geographical aspects:

• exchange transactions are related to a country and/or Users from a country with a high level of illegal activity or criminal drug trafficking;

• a User with a high degree of venality takes part in exchange operations;

• a User from a country to which intergovernmental sanctions are applied participates in exchange operations;

• other reasons that can increase the geographic danger.

5.4 Along with the dangers related to the User, the dangers concerning his partners and / or people related to them (for example, relatives) are also subject to assessment.

5.5 Hazard assessment is carried out by assigning each hazard category according to a 3-point system:

• the hazard is considered small when none of the groups contains a hazard factor and the exchange operations are more understandable;

• the danger is considered to be of medium degree if the causes of the danger for the operation itself are not transparent,

• although it is suspected that a combination of risk factors may indicate money laundering and/or sponsorship of banditry;

• the hazard is high if there are multiple hazards and the operation itself is not obvious.

The grand total is achieved by adding a cause from each group while the visitor and partner hazards are doubled, then the total is divided by 4.

• when the result is 2 or less, the danger is minimal;

• with a result of 2 to 2.75 - medium-level danger;

• with a result of more than 2.75 - the maximum danger.

When the danger in any of the groups is high, the total danger is considered to be maximum, regardless of the overall result.

6. Economic relations with the User

6.1 Any financial interaction with the User begins only after the User agrees to act in accordance with this AML policy and the Service Principles.

 

7. Reaction in case of fear of money laundering and the requirement to provide data

7.1 In the event of any suspicion before the start of financial interaction or in the process of applying regulatory methods that transactions may be related to money laundering and / or sponsorship of banditry, then further interaction is not allowed.

7.2 Any suspicions are recorded and investigated by the contact person fighting money laundering. The Estonian money laundering department and the Estonian Financial Inspectorate are obliged to immediately familiarize them with the results of the study.

7.3 All data on any transactions in excess of 32,000 euros must be submitted to the Estonian Money Laundering Prevention Department and the Estonian Financial Supervision Authority.

7.4 In the event that refraining from carrying out the operation will provoke losses for the visitor or lead to the detention of a person suspected of money laundering or sponsoring banditry, the operation can be postponed or carried out if the information is reported to the financial inspectors as soon as possible.

7.5 All data provided to the Financial Controllers shall be archived in accordance with the Secrecy Program and this program, including the results of information research.

 

7.6 Persons who are suspected of money laundering or banditry sponsorship are not allowed to provide any data on suspicions or notify about it in any other way.

 

8. Conducting correspondence

8.1 In the event that the administration considers it appropriate for the method of regulating implementation, it is possible to initiate correspondence with strangers, including banking and other commercial institutions, if this will contribute to obtaining correct data.

8.2 Correspondence must be presented in the format of the agreement of both parties, including the applied methods of regulation.

8.3 Correspondence is not permitted with illegal banking institutions, unlicensed companies and/or companies located in jurisdictions that do not comply with intergovernmental anti-money laundering and anti-gang sponsorship law standards.

 

9. Data capture program

9.1 The data recording program determines the responsibility of the employee of the organization that performed the exchange transactions, the creation of internal documentation containing all the features of the transactions, including:

9.1.1 Group of operations, factors affecting the degree of danger;

9.1.2 Detailed data on the exchange, including volume and currency;

9.1.3 Detailed information about the citizens participating in the exchange;

9.1.4 Details of the various ancillary controls applied to operations;

 

10. Cancellation program (exchange)

10.1 In the event that the User fails to provide, despite his obligations, the necessary document in accordance with the methods of regulation, the applicable law and these principles, the exchange will not be available to the User.

10.2 If the User does not provide data on the origin of money when requesting the Service, the exchange will not be available.

10.3 Data about the unavailability of the exchange must be stored in accordance with this program, the Principles of Service and the Privacy Program.

10.4 If exchange transactions are prohibited, the following data is stored:

• data about the circumstances of the ban in the exchange and account blocking;

• any circumstances of the prohibition of interaction in the field of exchange;

• data that caused a notice to government agencies under section 32 of the Anti-Money Laundering and Sponsoring of Terrorism Act.

10.5 The decision to prohibit transactions can be canceled if the visitor provides the necessary data in full, and they pass verification, or if such is decided by the decree of the following authorities:

• the regulatory body of the Republic of Estonia;

• qualified Estonian justice.

• Service Training Program

11.1 The Anti-Money Laundering and Gang Sponsoring Training Program takes place in accordance with these laws and includes the necessary instructions for employees regarding how to regulate and research data. Each employee must receive the necessary instructions from empowered employees within one month from the commencement of activities.

 

12. Internal Regulation Review Program

12.1 The Internal Regulation Review Program ensures that the employees of the Service comply with the principles of the law in force in the field of combating money laundering and the sponsoring of banditry. The program ensures that employees adhere to the internal rules and the Service program in the field of internal regulation.

12.2 Internal regulation assumes the following:

12.2.1 Every six months, it is necessary to conduct internal audits in the field of conscientious implementation of internal rules and applicable law;

12.2.2 The Head of the Service must continuously receive reports on all shortcomings of the internal order in the field of combating money laundering and preventing the sponsorship of banditry;

12.2.3 All deficiencies identified during the inspection process must be corrected in an appropriate way using the means chosen by the administration of the Service.

 

13. Program of Work Documentation

13.1 All documentation related to the user verification process and all data on the initial stage of financial interaction must be stored in the organization"s file cabinet during the period of use by the User of the Service, but not less than five years.

13.2 All documentation that has become the basis for the notification of public authorities is stored for a period of at least five years.

13.3 All data on claims made in order to comply with the rules used by law must be stored for at least 5 years from the start of commercial interaction. When confirming the identity with a digital document, a photograph of the face and an autograph are saved for at least a five-year period from the date of completion of economic interaction.

13.4 Records must be retained in a form that allows them to be reproduced in writing, for greater accessibility for the purpose of financial regulation or other public authorities according to the law in use, if they are necessary for use in civil, criminal or freelance investigations.

The principles of internal regulation establish the secrecy standards for data obtained in the course of verification and / or other operations, provided for by this law.

 

14. Requests from legal authorities

Anti-money laundering and banditry sponsoring companies can send their requests to our e-mail regarding actually conducted illegal operations.

Feedback address: [email protected].

We study only formal requests on forms of the established sample with all the necessary stamps and autographs. We also need to receive contact information for communication, as well as be able to verify the validity of the request. The waiting time for a response to a request from different jurisdictions can be completely different due to many factors, including, but not limited to, time zones, path, ability to communicate with fast communication channels, etc.