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Nuevo Digital Token (NVOD) ANTI MONEY LAUNDERING ("AML") AND KNOW YOUR CLIENT (KYC)

Nuevo Digital Token (NVOD) is committed to the highest standards of the Anti-Money Laundering (AML) compliance and Anti-Terrorist Financing and requires the management, and employees to follow the named standards.

Scope

This Policy outlines the minimum general unified standards of internal AML control which would be adhered to by the company in order to mitigate the legal, regulatory, reputational, operational, and as a consequence financial risk.

Objectives

The objective of the guidelines is to prevent the company from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities. The Policy also enables the company to know / understand status of its Investors / users and their financial dealings better, to manage risks including reputation.

Overview

Nuevo Digital Token (NVOD), like most companies providing services in the crypto market, adheres to the principles of Anti-Money Laundering and actively prevents any actions that aim or facilitate the process of legalizing of illegally gained funds. AML policy means preventing the use of the company's services by criminals, with the aim of money laundering, terrorist financing or other criminal activity. For this purpose, a strict policy on the detection, prevention and warning of the corresponding bodies of any suspicious activities was introduced by the company. Moreover, Nuevo Digital Token (NVOD) has no right to report users that the law enforcement bodies are informed on their activity. A complex electronic system for identifying every company's user and conducting a detailed history of all operations was introduced as well.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Terrorist financing is an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. The process of money laundering can be divided into three

sequential stages:

Placement. At this stage funds are converted into financial instruments, such as checks, bank accounts, and money transfers, or can be used for purchasing high-value goods that can be resold. They can also be physically deposited into banks and non-bank institutions (e.g., currency exchangers). To avoid suspicion by the company, the launderer may as well make several deposits instead of depositing the whole sum at once, this form of placement is called smurfing. Layering. Funds are transferred or moved to other accounts and other financial instruments. It is performed to disguise the origin and disrupt the indication of the entity that made the multiple financial transactions. Moving funds around and changing in their form makes it complicated to trace the money being laundered.

Integration. Funds get back into circulation as legitimate to purchase goods and services. In response to the scale and effect of money laundering, the United States of America and the European Union and many Governments has passed Laws and Directives designed to combat money laundering and terrorism. These Acts, together with other regulations, rules and industry guidance, form the cornerstone of our AML/KYC obligations and outline the offenses and penalties for failing to comply. Whilst Nuevo Digital Token (NVOD) business domain is currently relatively unregulated and does not fall within the scope of the AML/KYC obligations, our management has decided to implement systems and procedures that meet the standards set forth by the United States of America and the European Union. This decision reflects the management’s desire to prevent money laundering and not be used by criminals to launder proceeds of crime.

ANTI-MONEY LAUNDERING POLICY

Nuevo Digital Token (NVOD) has developed and will currently implement on a case-by-case basis a risk-based anti-money laundering program comprising of:

  • Written Anti-Money Laundering Policies
  • Customer Identification Procedures
  • Anti-Fraud Procedures
  • Record-Keeping Requirements
  • Customer Risk Assessment Procedures
  • Sanction Lists Procedures
  • Nuevo Digital Token (NVOD) Employees Training Procedures
  • On-going Customers’ activity procedures

The Nuevo Digital Token (NVOD) AML Policy is designed to prevent money laundering by meeting the worldwide standards on combating money laundering and terrorism financing, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:

  • Establishing and maintaining a Risk-Based Approach (RBA) to the assessment and management of money laundering and terrorist financing risks faced by the firm;
  • Establishing and maintaining risk-based Customer Due Diligence (CDD), identification, verification and Know Your Customer procedures, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs);
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