Regulations require the Company to have:

  • Policies and procedures to prevent them from being used by money launderers.
  • Employees trained in these procedures and in anti-money laundering law.
  • Checks and controls to ensure that the policies and procedures are working.
  • Have internal and external measures in place for the disclosure procedures for suspicious transactions.

Policies, controls and procedures sets out the requirement for relevant businesses to establish and maintain appropriate and risk-sensitive policies and procedures.

These policies and procedures must:

  • Identify and scrutinize
    • Complex or unusually large transactions
    • Unusual patterns of transactions which have no apparent economic or visible lawful purpose
    • Any other activity which could be considered to be related to money laundering or terrorist financing
  • Specify the additional measures that will be taken to prevent the use of products and transactions that favor anonymity for money laundering or terrorist financing
  • Determine whether a customer is a politically exposed person
  • Nominate an individual in the organization to receive disclosures.
  • Ensure employees report suspicious activity to the Contact person, and
  • Ensure the Contact person considers such internal reports in the light of available information and determines whether they give rise to knowledge or suspicion or reasonable grounds for knowledge or suspicion of money laundering or terrorist financing.
  • Financial institutions (which include bureau de change, money transmitters and cheque cashers) must, additionally:
    • Establish and maintain systems which enable a full and rapid response to enquiries from law enforcement agencies, and
    • Communicate the policies and procedures to branches and subsidiary undertakings which are located outside the Republic of Estonia.

Considering client`s identity

All persons and their representatives, who are applying to establish any business relationship with Zrx LTD OU, shall verify the client’s identity. The personal recognition or the publicity of the client or his representative does not exclude the compliance with the Guide’s obligation to detect money laundering or terrorist financing.

Upon establishing a business-relationship with a client, whether he/she is a sole proprietor or the representative of the client’s legal person, he/she shall be identified by means of IT instruments. The identification and control of a person’s identity shall be carried out upon the use of a bank link, ID-card, mobile-ID, Smart-ID, etc. In addition, the communication means, which are accessible only to the client or the client’s representative (e.g., @ or other exclusive mail) or/and the unique user ID of Zrx LTD OU, including the authentication tools shall be applied. If these documents or e-identification tools are unavailable, then the client shall identify his/her person with a photocopy of the identifying document copy of Zrx LTD OU. Prior to each transaction, the staff member shall ensure that the person / representative was previously identified and has a representation right.

The client shall submit his personal data. Full list of requirements are stipulated at Privacy Policy page.

The ground for the representation right in the case of an authorized person, the document, certifying the representation right notarial or through other equally authorized procedure, which is legalized or approved by a certificate replacing organization (apostille), unless otherwise is provided by an international agreement. Notarized copies of the aforementioned documents shall be sent via post.

In case, when the amount of the transaction, carried out by the client exceeds 15000 EUR, the client shall submit a copy of his bank account statement or an extract from his/her local government account, which may not be older than three months and indicates the name and address of the client.

To verify the information gathered, the member of the administrative staff shall use the available registers and the information contained on the Internet. In case of a business-relationship with a higher risk profile the information and the supporting documents from the submitters may be required. In case of doubts, the client shall be questioned on the grounds of the data gathered via the contact phone talk.

Due diligence measures

The due-diligence measures may be applied under the following conditions: In relation to the group of persons, specified in § 34 (2)1)-6) of the Act. If the client has been given written durability of the agreement; If the administrative staff doesn’t have doubts regarding the accuracy of the information provided by the Client or regarding the Client’s ability to provide such information; If the contact person doesn’t suspect any money laundering or terrorist financing in relation to the transaction; If the client’s risk or the transaction risk have ground to be considered low; If the client has already established a business-relationship before the implementation of the Guide or the client’s identity was identified after the implementation of the Guide pursuant to the rules of the Guide.

  • Zrx LTD OU shall apply the due diligence measures, described in the Act or to the extent, based on the nature of the business of Zrx LTD OU and to the extent necessary of the risk level, involved in the transaction.
  • Zrx LTD OU shall pay great attention to the activities and the circumstances of the client, which refer to money laundering or terrorist financing or the circumstances, upon which the client is definitely linked with money laundering or terrorist financing.
  • Prior to establishing a business relationship with a client, making a transaction, and applying for a business relationship, Zrx LTD OU shall apply the following due diligence measures:
  • Client identification, the verification of the submitted information, data retention and the update of an information;
  • The identification and the verification of the identity of the client’s representative, including his representation rights. The scope of powers, granted to the representative of the client shall be specified, whether there is a long-term business-relationship or one-time transaction, and whether the right of the representation allows Zrx LTD OU to enter into business-relationship;
  • The identification of the actual beneficiary;
  • Obtaining information regarding business-relationship, including the information about the nature and the purpose of the transaction;
  • Daily maintenance and vigilance in dealing with the client, including transactions performed during the business relationship, monitoring, regular checking of the data used to identify the person, the updates of the relevant documentation, data and information and, if necessary, the resources used in the transaction source and person identification.
  • To inform the contact person about the situations, when the transaction content or client's activities may contribute money laundering or terrorist financing and, if possible, to stop carrying out such kind transactions.

The due diligence measures may be applied not only upon the use of IT instruments, but also based on the facts identified pursuant to the original documents, which the client submitted. The original document cannot be obtained; the notarized or officially certified by the lawyer copies may be applied. Any other copies cannot be used, even if there is any doubt, that they may be compared against the original.

Update of data and documents, the measures of the internal control

  • The data shall be updated at least every two years.
  • The administrative staff is responsible for the relationships with the client (client’s manager) and he/she shall pay much attention to:
  • The customer’s data. In addition to the annual analysis, the client’s manager shall be constantly on track to evaluate the potential risks of money laundering and terrorist financing related to the business of the client and shall immediately notify the contact person about the change in a risk profile of the client.
  • The contact person shall draw up a detailed monitoring plan, based on the report finding, on the grounds whereof, the contact person monitors the transactions with the higher risk and the client’s profile.

The updated data shall be immediately entered by the contact person in the computer system of Zrx LTD OU, where the data will be available to the other administrative staff members. The contact person shall organize the management, the process of updating and analyzing of the inclusion data and enter the results into data storage to evaluate all risks, to prepare the action plan and to counsel with the managers to prevent risks.

Restrictions on transactions

The administrative staff member is prohibited:

  • To settle in cash;
  • To execute a transaction for the unidentified customers pursuant to the rules of the Guide;
  • To execute transactions for the anonymous or the fictitious persons, who use other names or denominations.

The administrative staff member of Zrx LTD OU shall refuse to execute a transaction, when:

  • The documents or other information, submitted by the client, is suspected in the accuracy and the client cannot adequately explain the circumstances that caused the doubt;
  • The client’s identity or credentials cannot be established or verified;
  • The client’s place of residence or occupation or type of activity or profile cannot be identified;
  • The client appears to be in the list of the imposition of the international sanctions or the client’s money laundering is identified by the FIU as a lender of suspicion in money laundering or terrorist financing, in case, when such information is disclosed by Financial Intelligence Unit;
  • When there are the circumstances, where there is a suspicion that a person may be involved in money laundering or financing of terrorism.
  • A refusal to execute a transaction is registered in the computer system of Zrx LTD OU.

Monitoring and analysis

  • The administrative staff member of Zrx LTD OU shall monitor and analyze whether the client is executing a transaction, is involved in money laundering or terrorist financing.
  • If the client's activity refers to money laundering or terrorist financing, the administrative staff member shall request from the customer the additional information in order to explain the origin of money.
  • The contact person shall analyze the client’s transactions, to clarify the possible connection with the money laundering transaction or an opportunity of nonmonetary origin of money, if it is necessary.
  • The contact person, who is responsible for managing of the risk assessment of money laundering and terrorist financing shall regularly analyze, whether in Zrx LTD OU terrorist financing or money-laundering risk factors may occur, and what does the Guide not cover.
  • The contact person shall analyze the client’s blockchain transactions and wallet to clarify the possible connection with the money laundering transaction or origin of Cryptocurrency via service. Zrx LTD OU will investigate on origins of bitcoins, operate anti-money laundering and due diligence procedures, and finally analyze customers profiles

Staff Training and Reporting

Training on the AML Policy will be given to all new employees before they start work and will be repeated every 12 months as a refresher. The staff has to be instructed in the risks of money laundering/terrorism financing and in the identification and reporting of unusual activities or transactions which may prove to be suspicious. We will also carry out training where there has been a substantial change in the law, and there will be monthly training sessions on various other relevant topics. Regular reviews are held to ensure all procedures and processes have been adhered to with all customer registrations and ensuring that business transactions have been completed correctly.

Contact person

The contact person is the person within an organization who is responsible for overseeing all activity related to anti-money laundering matters. The contact person is appointed by the management board. Zrx LTD OU Board informs the Financial Intelligence Unit immediately.

The contact person`s responsibilities include:

  • The contact person has the right to require all staff members to comply with the obligations set forth in the Guide, and to terminate possible violation immediately.
  • Reviewing all new laws and deciding how they impact on the operational process of the company
  • Preparing a written procedures manual and making it available to all staff and other stakeholders
  • Making sure appropriate due diligence is carried out on customers and business partners
  • Ensuring staff receive anti-financial crime training when they join and that they receive regular refresher training
  • Monitoring business relationships and recording reviews and decisions taken
  • Making decisions about continuing or terminating trading activity with particular customers
  • Making sure that all business records are kept for at least five years from the date of the last customer transaction as per The Money Laundering and Terrorist Financing Prevention Act

Measures of the internal control

  • Zrx LTD OU shall control the execution of anti-money laundering and anti-terrorist financing measures.
  • In addition, the contact person shall carry out an internal check at least once a year,where:
    • The compliance with the requirements of the Guide shall be checked; The compliance of registrations with the Guide shall be checked;
    • The fulfillment of other requirements for the prevention of money laundering and terrorist financing shall be checked;
    • The compliance of the business relationship, monitoring procedures pursuant to the Guide shall be checked

The contact person shall draw up a report on the execution of the internal control.

  • In the course of ongoing and annual supplementary inspections, the contact person is entitled:
    • To monitor the work of the administrative staff management and to obtain the technical means necessary for this;
    • To demand the immediate termination of non-compliance with anti-money laundering and anti-terrorist financing requirements;
    • To make suggestions for eliminating of the shortcomings identified during the verification pursuant to the procedural rules.