AML Policy

GENERAL PROVISIONS

LEMFT shall comply with the requirements contained in various international Anti-Money Laundering laws and regulations to the extent to which they relate to LEMFT's operations.

LEMFT shall strictly adhere to the policies and procedures outlined in this document (hereinafter – the AML Policy). LEMFT retains internal policies to address AML compliance procedures in detail.

LEMFT develops this AML Policy, introduces amendments and additions to it at its own discretion, and oversees compliance with its provisions and requirements. LEMFT also adopts internal policies and procedures to ensure compliance with anti-money laundering and terrorist financing laws.

COMPLIANCE OFFICER

To oversee and implement the procedures reflected in the AML Policy, LEMFT appoints the Compliance Officer.

The Compliance Officer is responsible for the collection, analysis, and investigation of information on any suspicious activities and the training of LEMFT's employees pertaining to the detection, prevention, and reporting of financial crimes, regulatory violations, and compliance with applicable laws and industry standards.

Compliance Officer will retain records of all documentation that have been relied upon for client/corporation identification.

CUSTOMER IDENTIFICATION POLICY

LEMFT uses the procedures for identification and verification of Customers that vary in complexity depending on transaction amounts.

For the purposes of Customers' identification, LEMFT requests the following documents:

To verify an individual:

• proof of identity (passport, driving licence, national identity card);
• proof of address (bank statement, utility bill);

To verify a business corporation:

• all the documents required to verify a personal account;
• incorporation documents for a company, including: state registration certificate (certificate of incorporation); company's charter; Articles of Incorporation (if available); document confirming the powers and authority of the person authorized to act on the company's behalf without a power of attorney, etc.

TRANSACTION MONITORING AND PROCESSING

LEMFT applies various checking and monitoring algorithms to make sure all required KYC procedures are executed in a timely manner, persons with limitations (sanctions list and politically exposed persons screening) are detected, and comprehensive automated online monitoring is carried out.

Financial data analysis includes several major components:

• Monitoring of sanctions lists;
• Monitoring of user activity and user system environment;
• Transaction monitoring;
• Analysis of remaining balances, exchange rate fluctuations and other aspects;
• Tools enhancing manual data analysis possibilities;
• LEMFT applies risk-based approach to define account and transaction risk level.

IDENTIFICATION AND DETECTION OF SUSPICIOUS ACTIVITIES

LEMFT understands the importance of identifying and detecting suspicious activity through monitoring and reviewing the activity of customer transactions. Any financial transaction that may be related to money laundering activities shall be considered to be suspicious activities.

Grounds for determining that a specific transaction is suspicious may be personal observations and experience of LEMFT's employees, as well as information received or identified. Suspicious activity includes a transaction that any employee knows or suspects to: involve proceeds from an illegal activity; evade currency transaction reporting requirements; vary significantly from the customer's normal transactions; a third party gained access to the customer's account or the activities are performed under instructions of a third party; or has no business or apparent lawful purpose and LEMFT knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction.

LEMFT will apply enhanced scrutiny to manually monitor customer transactions, in a manner reasonably designed to detect money laundering and suspicious activity. To identify suspicious transactions, LEMFT is entitled to perform enhanced due diligence measures and request additional information from the client confirming the economic purpose of the transaction and the origin of funds.

The Compliance Officer shall continuously monitor and update the systems used by LEMFT to detect suspicious activities.

In accordance with the applicable laws and regualtions where LEMFT carries out its business and the requirements of international organizations, LEMFT may, where appropriate and without the obligation of obtaining the Customer's approval or notifying the Customer, notify regulating and/or law enforcement agencies of any suspicious transactions.

Different requirements for reporting suspicious transactions may depend on the nature and amount of a transaction.

LEMFT shall periodically refer to and consult the lists published by the authorities and international organizations that contain lists of known terrorists or persons suspected of terrorist activities, terrorist organizations, high-risk countries, a limited list of countries subject to the OFAC sanctions, jurisdictions that do not provide sufficient level of anti-money laundering procedures, as well as countries subject to sanctions to determine whether LEMFT's Customer or potential Customer, and/or such Customer's country of jurisdiction is included in the above lists.

LEMFT shall continuously conduct due diligence procedures pertaining to its Customers and scrutinize transactions carried out by them to ensure these transactions' compatibility with LEMFT's knowledge of its Customers, their business and, when necessary, their source of funds.

THIRD PARTIES

To perform some of its business functions, LEMFT uses third-party service providers. LEMFT shall try to determine, during the initial and ongoing due diligence process, to the extent possible whether there are any initiated investigations and filed lawsuits against any such third-party service providers. LEMFT shall also determine whether a third-party provider has obtained all the necessary licences (if applicable), permits, and approvals before establishing a business relationship with such third-party service provider.

Regarding its own staff, LEMFT shall carefully review all candidates for employment and determine whether the activities of a new employee fall in the category that is susceptible to money laundering activities. In addition, LEMFT has prepared and implements a number of personnel training programs on customer identification procedures and prevention of money laundering activities.

CIVIL AND CRIMINAL PENALTIES

Government authorities of different countries and, in some cases, international organizations, may impose severe civil and criminal penalties against any person who violates the laws and regulations referred to in the AML Policy.

Under certain circumstances, companies may be deemed criminally responsible for the actions of their employees. In this regard, it is important for the employees of our Corporate Customers to have adequate knowledge in this sphere; it is also important that such Corporate Customers should ensure the compliance of their employees' actions with the said laws and regulations.

COMPLIANCE STATEMENT

The Corporate Customer (the Corporate Customer's authorized employee) certifies that they have read and understood this AML Policy, and that they (or their company) shall operate in full compliance with the requirements and standards outlined in the AML Policy and comply with all applicable laws and other regulations and requirements governing its activities as a Corporate Customer.

The Corporate Customer (the Corporate Customer's authorized employee) acknowledges that they are responsible for their actions in accordance with the effective AML laws and shall bear responsibility pertaining to failure to comply with such laws.