Licensecrip s.r.o. Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Policy

ID: ​21260966, with registered office at ​Cimburkova 916/8, Žižkov, 130 00 Praha 3

Last update 25.03.2024

Licensecrip s.r.o. Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Policy Enhanced Version 1. Customer Acceptance and Due Diligence (CDD) Customer Due Diligence Process: Collecting and verifying the customer's full name, date of birth, address, nationality, ID number, and other relevant information. Obtaining and verifying a copy of the customer's ID document or passport. Assessing the customer's risk profile, checking against PEP (Politically Exposed Persons) and sanctions lists. Requesting additional documentation and information for high-risk customers, such as proof of employment, source of income, etc. Customer Acceptance Procedures: Applying simplified, standard, or enhanced KYC procedures based on the customer's risk profile. Conducting regular checks to keep the customer's identification information and documents updated. Requesting additional documentation and information if there are any changes in the customer's risk profile or activities. 2. Suspicious Transaction Reporting (STR) Suspicious Transaction Indicators: Unusual or suspicious money transfers, such as large value transfers, international transfers, frequent small value transfers, etc. Inconsistencies in the customer's identity or activities, such as mismatch between customer's declared information and documents, customer's activities not consistent with source of income, etc.

1. Customer Acceptance and Due Diligence (CDD)
  • Customer Due Diligence Process:
    • Collecting and verifying the customer's full name, date of birth, address, nationality, ID number, and other relevant information.
    • Obtaining and verifying a copy of the customer's ID document or passport.
    • Assessing the customer's risk profile, checking against PEP (Politically Exposed Persons) and sanctions lists.
    • Requesting additional documentation and information for high-risk customers, such as proof of employment, source of income, etc.
  • Customer Acceptance Procedures:
    • Applying simplified, standard, or enhanced KYC procedures based on the customer's risk profile.
    • Conducting regular checks to keep the customer's identification information and documents updated.
    • Requesting additional documentation and information if there are any changes in the customer's risk profile or activities.
2. Suspicious Transaction Reporting (STR)
  • Suspicious Transaction Indicators:
    • Unusual or suspicious money transfers, such as large value transfers, international transfers, frequent small value transfers, etc.
    • Inconsistencies in the customer's identity or activities, such as mismatch between customer's declared information and documents, customer's activities not consistent with source of income, etc.
    • Transactions involving customers suspected of being linked to terrorist organizations or other illegal activities.
  • STR Process:
    • Appointing an AML/CFT Officer to identify and analyze suspicious transactions.
    • Reporting suspicious transactions to the relevant authorities (Financial Intelligence Unit) within 5 working days.
    • Documenting and recording STRs in detail and accurately.
3. Training and Awareness
  • Training Program:
    • Providing regular training to all employees on AML/CFT risks and company policies.
    • Customizing the training content based on the employees' risk profile and job description.
    • Monitoring changes in legal regulations and current developments and reflecting them in the trainings.
  • Awareness Raising Activities:
    • Sharing information and posters on AML/CFT throughout the company.
    • Creating Q&A platforms for employees on AML/CFT.
    • Conducting awareness raising activities on how to identify and report suspicious transactions.
4. Internal Control and Audit
  • Internal Control System:
    • Establishing an internal control system to monitor the effectiveness and compliance of AML/CFT policies and procedures.
    • Regularly auditing risk assessments, customer acceptance procedures, and the STR process.
    • Making necessary updates and improvements to policies and procedures.
  • Audit:
    • Having AML/CFT policies and procedures regularly audited by an independent auditor.
    • Submitting audit findings and recommendations to the management and taking necessary actions.
5. Policy Updates
  • Compliance with Legal Regulations:
    • Monitoring changes in AML/CFT legal regulations and reflecting them in the policy.
    • Complying with the current directives and regulations of the European Union and the Czech Republic regarding AML/CFT.
  • Risk Assessment:
    • Regularly assessing the company's AML/CFT risk profile and reflecting it in the policy.
    • Evaluating the AML/CFT risks of new products, services, and technologies and reflecting them in the policy.
  • Improvement Process:
    • Conducting regular reviews to identify gaps and areas for improvement in the policy.
    • Making necessary updates to ensure the policy is up-to-date and relevant to the company's risk profile.
6. Record Keeping and Reporting
  • Record Keeping:
    • Keeping detailed and accurate records of customer identification information, transactions, and STRs.
    • Storing records in accordance with legal regulations and presenting them to the authorities.
  • Reporting:
    • Preparing regular reports on the company's AML/CFT risks and the effectiveness of its policies.
    • Submitting reports to the management and relevant authorities.
7. Responsibilities and Authorities
  • Management:
    • The management is responsible for the overall AML/CFT policies and procedures.
    • It is the responsibility of the management to ensure that the policies are up-to-date and compliant with legal regulations.
  • AML/CFT Officer:
    • Responsible for the day-to-day implementation of AML/CFT policies and procedures.
    • Responsible for identifying, analyzing, and reporting suspicious transactions.
  • Employees:
    • It is the responsibility of all employees to comply with AML/CFT policies and procedures.
    • It is the responsibility of all employees to report suspicious transactions to the AML/CFT Officer.
8. Communication and Cooperation
  • Cooperation with Authorities:
    • The company declares its readiness to cooperate with the authorities in all matters related to AML/CFT.
    • It is ready to provide the necessary information and documents to the authorities regarding suspicious transactions and other AML/CFT related issues.
  • Communication with Customers:
    • The company commits to informing its customers about AML/CFT policies and procedures.
    • Customers are expected to comply with AML/CFT policies and procedures.
9. Conclusion
  • Licensecrip s.r.o. implements an AML/CFT policy for all its customers in compliance with Czech Republic and EU laws.
  • Licensecrip s.r.o. is committed to combating money laundering and the financing of terrorism and ensuring the transparency and reliability of its customers and transactions. This policy outlines the framework for how our company manages AML/CFT risks and complies with relevant laws and regulations.

    • Final Provisions

    • This Directive is an integral part of the Terms and Conditions and we may unilaterally amend or supplement it at any time.
    • By agreeing to the Terms and Conditions, you confirm that you have thoroughly read this Directive, fully understood it, accept it without reservation and will comply with it.