ANTI-MONEY LAUNDERING (AML) POLICY OF DENARIUS INVEST

This DENARIUS INVEST’s AML policy is directed at anti-money laundering derived from the illegal
activities.

What is Anti-Money Laundering?

Money laundering or in terms of law “legalising the proceeds of criminal activities”, i.e. actions that hide the
source of funds in order to make their nature lawful. Money laundering includes various manipulations with
monetary funds with the purpose of hiding their illegal origin. Illegally obtained funds, within the meaning
of the terms of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 of the Republic
of Ireland, means any property that is derived from or obtained through criminal conduct, whether directly or
indirectly, or in whole or in part.
Generally the money laundering derived from the illegal activities consists of three stages:
Placement: introduction of cash originating from illegal/criminal activities into financial or non-
financial institutions.
Stratification(layering): separating the proceeds of criminal activities form their source through
the use of layers of complex financial transactions. These layers are designed to hamper the audit
trail, disguise the origin of funds and provide anonymity.
Integration: placing the laundered proceeds back into the economy in such a way that they enter the
financial system as apparently legitimate funds.


Anti-money laundering (AML) incorporates a complex of measures aimed at prevention of use of the
Website of DENARIUS INVEST for money laundering, for instance, as result of rubbery, fraud, trafficking
in drugs and human beings and other illegal activities (disguising the illegal origin and criminal nature of
funds) or terrorism financing. The objective of fighting terrorism financing is to prevent the involvement of
DENARIUS INVEST in provision of financial support to terrorists or organization of terrorist acts.
DENARIUS INVEST pays special attention to compliance with the international requirements in the field of
the prevention of money laundering and terrorism financing. To this purpose DENARIUS INVEST has
implemented an internal control system which ensured in-depth research and analysis and operational control
of financial transactions performed through the Website of DENARIUS INVEST.
The Policy applies to all employees of DENARIUS INVEST and aims to setup key roles and responsibilities
for the staff members as well as to ensure compliance with the legislation in the field of the prevention of
money laundering.

How do we work?

  • We trust only highly competent personnel of DENARIUS INVEST who works in close contact with our Customers and Partners, our aim is full understanding and knowledge of our Customers and Partners with whom we enter into business relations.
  • We improve our AML policy and procedures continuously, and they comply with the requirements of normative acts of the Republic of Ireland, but in some aspects even excel such requirements. We make considerable investments in this process and ensure continuous training of our staff members in this area.
  • We purchase and work out independently new technologies that enable us to prevent possible attempts of money laundering.
  • We understand that anti-money laundering and statement of terrorism financing is a continuous process that requires constant attention and ability to monitor unlawful financial schemes.
  • We comply with the legal requirements of the Republic of Ireland for anti-money laundering. In cases set forth in the relevant legal acts, our Company cooperates with officials and government institutions of the Republic of Ireland.


In the light of mentioned above DENARIUS INVEST:

  • neither accepts nor disburses cash;
  • deals with Customers’ accounts opened with a credit establishment and/or authorized payment service provider registered in EU, EEA and Swiss Confederation;
  • neither accepting nor transferring funds to accounts of third parties;
  • our Customers funds are held by authorized payments service provider/credit establishment specified on Website of DENARIUS INVEST separate from the DENARIUS INVEST’s funds.


Identification of Customers

During the Customers’ registration process on our Website each of them shall be identified. For this purpose
the Company has worked out internal normative documents prescribing the careful examination of each new
Customer before becoming full registered user of the Website of DENARIUS INVEST.
In spite of the Customer does not need to be identified in the presence of the DENARIUS INVEST’s official,
we should not register the Customer, who does not have the bank account opened with a licensed credit
establishment or authorised payment service provider registered in EU, EEA or Swiss Confederation or a
branch of such credit establishment/payment service provider. The first payment should be made from such
account only, otherwise DENARIUS INVEST should refuse the registration to relevant Customer. During
the registration process DENARIUS INVEST and/or our partner - payment service provider holding our
Customers’ funds - uses the information relating to the Customer provided by the credit
establishment/authorized payment service provider from which account the payment has been made, as well
compares the information mentioned above with the information provided by the Customer itself while
filling in the registration application on the Website of DENARIUS INVEST. If during the identification
process any information relating to the Customer arises suspicions of our officials, DENARIUS INVEST
either refuses the registration to relevant Customer without notifying the reason, or requires additional
information.

Monitoring of payments

Each funds transfer made through our website is in-depth treated and examined by DENARIUS INVEST
and/or DENARIUS INVEST’s partner – payment service provider holding our Customers’ funds.
We also have worked out the range of internal documents containing analysis and monitoring criteria for
payments made through the Website of DENARIUS INVEST, which are taken into account during all
cooperation period with each relevant Customer and/or Partner.

Risk management and assessment

After risk assessment our Company applies appropriate measures and procedures to focus its effort in those
areas where the risk of money laundering and terrorism financing appears to be higher.
Risk assessment is not an isolated event of a limited duration. This is a continuous process, carried out on a
dynamic basis. The Customers’ activities change as well as the services provided by the Company. The same
happens to the transactions used for money laundering or terrorism financing.

Applicable law

  1. Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 available here
  2. Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC available here