Anti-Money Laundering (AML) Policy

Last updated on 22 january 2025.

OPTIMONEY, a company registered in Hamchako, Mutsamudu, Autonomous Island of Anjouan, Union of Comoros, operates under an international financial license with registration number 15912 (hereinafter be referred to as the “OPTIMONEY”, “we,” “us,” or “our”, “Company”). The company is committed to adhering to all applicable laws and regulations to combat money laundering and terrorism financing.

The Company operates the website/platform https://www.optimoney.com/ (hereinafter be referred to as the “Platform”, “Website/Site”).

The AML policy of OPTIMONEY underscores its commitment to legal compliance, risk mitigation, and maintaining client and partner trust. All employees must adhere to this policy and contribute to its effective implementation.

Objective

This policy's objectives are to:
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-       Ensure compliance with anti-money laundering (AML) and counter-terrorism financing laws and regulations.
-       Establish protocols for identifying and reporting suspicious activities.
-       Safeguard the reputation of OPTIMONEY and maintain the trust of clients and partners.
-       Prevent misuse of the company's services for illicit purposes.

Definitions

-       Money Laundering: The process of concealing the origins of illegally obtained funds to make them appear legitimate.
-       Terrorism Financing: The act of providing or collecting funds intended to support terrorist activities.
-       Suspicious Activity: Any transaction or behavior suggesting potential money laundering or terrorism financing.

Responsibilities and Duties

1. Board of Directors and Senior Management:
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-       Develop, implement, and oversee the AML policy.
-       Ensure sufficient resources are allocated for effective policy implementation.
-       Periodically review and update the policy to ensure compliance with current regulations.
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2. Employees:
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-       Comply with all AML policy requirements.
-       Participate in AML training programs and refreshers.
-       Promptly report suspicious activities to the AML officer.
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3. AML Officer:
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-       Coordinate all AML-related activities within the company.
-       Develop and implement client identification and monitoring procedures.
-       Report suspicious activities to the appropriate authorities in a timely manner.

Anti-Money Laundering Procedures

1. Customer Identification (KYC):
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-       Conduct a comprehensive "Know Your Customer" (KYC) process before establishing any business relationship.
-       Require individuals to submit valid identification and address verification documents.
-       Require legal entities to provide company registration documents, beneficial ownership information, and relevant identification for key personnel.

2. Risk Assessment:
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-       Classify all clients into low, medium, or high-risk categories based on factors such as geography, jurisdiction, and behavior.
-       Conduct enhanced due diligence and ongoing monitoring for high-risk clients.
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3. Monitoring and Reporting:

-       Continuously monitor client transactions to detect suspicious activities.
-       Document and report all suspicious transactions promptly to the relevant authorities.
-       Maintain comprehensive records of suspicious activity reports and client risk assessments.

Employee Training and Awareness

1. Training Program:
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-       Provide mandatory AML training for all employees, especially those in key operational roles.
-       Ensure training includes updates on emerging money laundering techniques, terrorism financing risks, and relevant legal changes.
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2. Awareness Initiatives:
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-       Conduct regular information sessions to raise awareness about recognizing suspicious activities and responding appropriately.
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3. Training Evaluation:
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-       Assess the effectiveness of training programs through periodic tests and employee feedback.
-       Use evaluation results to enhance and update training content.

Internal Checks and Audit

1. Planned Checks:
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-       Regularly conduct internal evaluations to verify compliance with AML policies and procedures.
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2. Audit:
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-       Perform independent internal audits to identify potential weaknesses in AML processes.
-       Present audit findings to the board of directors and implement recommended improvements.

3. Reporting:
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-       Document all audit results and maintain them as per legal retention requirements.

Compliance with Regulatory Requirements

1. Legislative Compliance:
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-       Adhere to all relevant AML regulations in the Union of Comoros and other operating jurisdictions.
-       Regularly update policies to reflect changes in applicable laws. 2. Reporting to Authorities:
-       Promptly report suspicious transactions to the designated regulatory authorities.
-       Cooperate with law enforcement and regulatory bodies to prevent money laundering and terrorism financing.

3. Collaboration with Financial Institutions:

-       Share information and best practices with other financial institutions to improve AML measures.

Documentation and Record Keeping

1. Record Maintenance:

-       Maintain detailed records of client identification, risk assessments, and transaction monitoring activities.

2. Confidentiality:

-       Treat all AML-related information as confidential and secure it against unauthorized access.
-       Restrict access to authorized personnel only.

3. Electronic Documentation:

-       Utilize advanced systems to securely store and manage records with encryption and access control.