This policy establishes Interactive Paper GmbH's commitment to comply with laws and regulations designed to combat money laundering, terrorist financing, and sanctions violations. This policy complements existing policies focused on ethical conduct and corruption prevention.
This policy is applicable to all Interactive Paper GmbH employees, management, contractors, third-party vendors, and business associates.
- : Regulations, procedures, and laws to prevent income generation through illegal actions.
- : Due diligence activities performed to ascertain the identity of customers.
- : Measures to prevent the funding of terrorist activities.
- : Anomalous or inconsistent activities or transactions that may signify money laundering, terrorist financing, or other illegal activities.
- : National and international laws that restrict trade, financial transactions, and other activities with specified countries, entities, and individuals.
A designated Compliance Officer is responsible for:
1. Overseeing and implementing the AML, KYC, and Sanctions Compliance Policy.
2. Coordinating and overseeing training programs.
3. Reporting to the Board of Directors and relevant authorities.
4. Periodic audits and risk assessments.
All employees are required to:
1. Understand and comply with this policy.
2. Report any suspicious activity to the Compliance Officer immediately.
3. Participate in periodic training and awareness programs.
For customers, the following information must be verified:
1. Business licenses.
2. Articles of incorporation.
3. Names of directors and ownership structure.
4. Tax Identification Numbers.
Each transaction must be scrutinized to ensure it aligns with the customer’s profile and business activities. Factors to consider include but are not limited to:
1. Transaction amount.
2. Geographical location.
3. Nature of payment.
A continuously updated list of entities and countries subject to sanctions will be maintained. Any transaction involving these parties must be flagged and reported to the relevant authorities.
Employees must file a Suspicious Activity Report (SAR) for transactions that appear to involve money laundering or fraud. These reports should be filed with the Compliance Officer within 24 hours of detecting the suspicious activity.
All KYC documents and transaction records must be retained for a minimum of five years and must be readily available for compliance checks and audits.
A comprehensive training program must be completed by all personnel within one month of employment and annually thereafter. The program will include:
1. Overview of AML, CTF, and Sanctions laws.
2. Identification and reporting of suspicious activities.
3. KYC best practices.
An internal audit of AML, KYC, and Sanctions compliance will be conducted annually. The Board of Directors must review and approve the policy bi-annually or more frequently if required by law or regulatory changes.
Failure to comply with this policy will result in disciplinary action, up to and including termination. Legal repercussions may also apply.
By adhering to this policy, Interactive Paper GmbH reaffirms its commitment to operating in a legally compliant and ethical manner. This policy is a dynamic document and will be updated as necessary to reflect changes in law, regulation, and business operations.