Effective Client Due Diligence (”CDD”) measures are essential to the management of money laundering and terrorist financing risk. CDD means identifying the Client and verifying their true identity on the basis of documents, data or information both at the moment of starting a business relationship with Client and on an ongoing basis. The Client identification and verification procedures require, first, the collection of data and, second, attempts to verify that data.

During the account registration process an individual Client provides the following identification information to the Company:

• Client’s full name;
• Client’s date of birth;
• Country of residence/location of Client;
• Mobile telephone number and e-mail.

During the account registration process a corporate Client provides the following identification information to the Company as a minimum:

• Full company name;
• Registration number and date;
• Country of registration/incorporation;
• Registered address;
• Mobile telephone number and e-mail.
• Names of Directors
• Names of Shareholders up to the ultimate beneficial owners (UBOs).

Appropriate documents for verifying the identity of Client include, but are not limited to, the following:

• A high-resolution copy of a utility bill (fixed-line phone, water, electricity) issued within the last 3
  months;
• A copy of a tax or rates bill from a local authority;
• A copy of a bank statement (for a current account, deposit account or credit card account);
• A copy of a bank reference letter.

The information and documents will be automatically verified by the Company’s electronic system or 3rd party identity verification software or by the Company’s staff. The Client’s information is verified against electronic databases for confirmation of identity details and legal status such as criminal record, political associations, sanctions lists etc.

The 3rd party system that is used by the company for verification purposes fulfils the below conditions:

1. Is registered with the Data Protection Commissioner in the country from which it operates, for the purposes of safety or the personal data and
2. Electronic databases provide access to information that refers to both current and previous situations that indicate that the person actually exists and include positive information (at least full name, address and date of birth of the Client) as well as negative information (e.g. committing offenses such as identity theft, inclusion in files of deceased persons, inclusion in lists of sanctions and restrictive measures by the Council of the European Union, Interpol and the Security Council UN).
3. Uses multiple sources of information which update in real-time as well as present alerts whenever information in the system regarding a verified client, will change (e.g. A previously verified client has now been added to a sanctions list)
4. Provide details as to what kind of information was researched and resulted in either validation or invalidation of the client’s verification.
5. Allows the Company to keep records of the information that was verified as well as the verification results.
6. Electronic databases contain a wide range of sources, with information from various time intervals, updated to real-time update and send notifications trigger alerts when important data is differentiated.
7. Has established transparent procedures that allow to the Company to identify what information has been searched for, which ones are their effects and their importance in relation to the degree certainty as to the identity of the Client.

Potential sanctions matches are reviewed by the responsible persons and if the matches are found to be accurate and true the Client gets rejected.

When making a funds deposit or funds withdrawal via credit/debit card which is not 3D Secure, a Client is required to provide a scanned copy or photo of the credit/debit card (front and back side). The front side of credit/debit card should show the cardholder’s full name, the expiry date and the first six and the last four digits of the card number (the rest of the digits may be covered). The copy or scan of the reverse side of credit/debit card should show the cardholder’s signature, but the CVC2/CVV2 code must be masked.

If an existing Client either refuses to provide the information described above or if a Client has intentionally provided misleading information, the Company, after considering the risks involved, will consider closing any of the existing Client’s accounts.

The Regulations measures require further research and identification of Clients who may pose a potentially high risk of money laundering/terrorism financing. If the Company has assessed that the business relationship with a Client poses a high risk, it will apply the following additional measures:

• Obtaining the information relating to the source of the funds or the wealth of the Client will be required (this will be done via e-mail, Client Portal ticketing system or phone);
• Seek further information from the Client or from Company’s own research and third-party sources in order to clarify or update the Client’s information, obtain any further or additional information, clarify the nature and purpose of the Client’s transactions with Company.

When obtaining information to verify the Client’s statements about source of funds or wealth, the Company’s staff will most often ask for and scrutinize details of the person’s employment status or business/occupation. The Company’s staff will ask for whatever additional data or proof of that employment/occupation that may be deemed necessary in the situation, particularly the appropriate confirming documents (employment agreements, bank statements, letter from employer or business, financial statements etc.).

The Company will conduct ongoing Client due diligence and account monitoring for all business relationships with Clients. It particularly involves regularly reviewing and refreshing Company’s view of what its Clients are doing, the level of risk they pose, and whether anything is inconsistent with information or beliefs previously held about the Client. It can also include anything that appears to be a material change in the nature or purpose of the Client’s business relationship with Company.

The Company’s Refund Policy is an integral part of the Client Agreement and can be found on the Company’s website at www.finsaitrade.com The Refund Policy contains all the relevant information regarding payments to and from the Company and measures taken prevent money laundering and terrorist financing.