To mitigate risks associated with the legalization of funds from criminal activities and terrorism financing, ILERITER sp. z o.o.implements a comprehensive set of Anti-Money Laundering (AML) rules and measures.
Money laundering involves disguising the illicit origins of assets or obstructing their traceability through the services of ILERITER sp. z o.o. Similar AML regulations are mandatory for comparable businesses in Poland and other countries, as money laundering and terrorism financing are often carried out on an international scale.
ILERITER sp. z o.o. regularly conducts checks to ensure that customers are not subject to international sanctions and adheres to additional procedures as outlined below.
For the purposes of this document, the AML Act refers to the Act of March 1, 2018, on Counteracting Money Laundering and Financing ofTerrorism (the “AML/CFT Act”), which addresses measures against the legalization of revenues from criminal activities and terrorism financing. ILERITER sp. z o.o. has appointed a Compliance Officer responsible for implementing the AML policy, including but not limited to, the activities listed below.
‍AML PROTOCOLSThe company follows these AML protocols:
‍1. Client Identity Verification:We thoroughly verify the client's identity before entering into any business relationship.     
‍2. Risk-Based Client Due Diligence:We implement and maintain a client due diligence system that is tailored to the assessed risk level, applying increased scrutiny for clients identified ashigher risk.       
‍3. TransactionMonitoring: We continuously monitor transactions based on detailed risk assessments.       
‍4. Reporting Suspicious Activity:We promptly report any suspicious activities internally and notify the relevant authorities when required by applicable laws and regulations.
‍5. RegularAML Training: We conduct regular and comprehensive AML training sessions for our team members to ensure they are updated on the latest protocols and practices.
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‍IDENTITY VERIFICATION PROCESS
‍To maintain the integrity of our services and meet legal requirements, ILERITER sp. z o.o. must verify the identity of each customer before granting access to our services. This process is crucial for preventing terrorism financing and money laundering. Financial institutions are legally obligated to collect, verify, and record identifying information from anyone seeking to engage in transactions with us. As such, we will require your name, address, date of birth, and other relevant details about you, your organization, or associated individuals before processing any transactions.If a customer is determined to have a higher risk profile, ILERITER sp. z o.o. will conduct a more in-depth investigation, which may involve requesting additional information and extending the verification period.We also reserve the right to continuously verify a customer's identity, particularly if there are changes in identification details or if the customer’s activities appear suspicious or irregular. We may request updated documents from the customer even if previous verifications have been completed.All collected identification information will be managed in strict accordance with ILERITER sp. z o.o.'s Privacy Policy and relevant regulations, ensuring that it is securely collected, stored, and shared.
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‍IDENTITY VERIFICATION REQUIREMENTS
‍Users are required to provide the following information:
·     Full name.
·     State-assigned identification number (supported by documents such as a photocopy of a national ID, international passport, or other identification documents).
·     Date of birth.
·     Nationality.
·     Telephone number.
·     Email address.
·     Address (supported by documents such as a bank statement and a utility bill as proof of address).
·     Other information or documents requested by the Company (e.g., a photograph of the Client, documents confirming the source of funds).
If a more thorough verification is needed, Users may be asked to provide additional documents for identity, address, and financial status verification as per this AML-KYC Policy.

The additional documents required are:
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For Individuals:
·     IdentityDocument: A color copy of a passport or another recognized identity document from the user's country of residence.
·     Government-Issued Document: A document such as a tax statement that clearly shows the individual's residential address.
·     Bank Statement: A statement dated within the last 3 months.
·     Utility Bill: A bill dated within the last 3 months.
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For Legal Entities:
·     Corporate Documentation: A copy of the extract from the protocol of the general meeting of participants/shareholders, a certificate of directors and secretary, minutes of the first meeting of directors, a register of directors, or another document verifying the appointment of directors or equivalent documentation confirming the registration of corporate acts and amendments and the authority of the company head.
·     Head's Identity Document: A copy of the passport of the company head (or passport copies of all individuals who, directly or indirectly, own more than 25 percent of the company's share capital, if required).
·     Location Confirmation: A document verifying the legal entity’s location or business address (such as a utility bill dated within the last 3 months or a copy of the office rental agreement).
·     Certificate of Incorporation: A copy of the certificate of incorporation.
·     Memorandum and Articles of Association: A copy of the memorandum and articles of association or an equivalent document, duly registered with the appropriate authority.
·     Shareholders Certificate: A certificate of shareholders or a register of members.
·     Bank Reference Letter: A reference letter from the bank confirming the opening of a current account, or a copy of the bank contract for account opening.
·     Certificate of Good Standing: A copy of the certificate of good standing.
‍RISK ASSESSMENTILERITER sp. z o.o. follows a risk-based approach to meet its obligations under Anti-Money Laundering (AML) and Counter-Terrorist Financing(CTF) regulations. This approach helps us identify, assess, and understand the risks related to money laundering and terrorist financing that ILERITER sp. zo. o. may face, allowing us to implement appropriate mitigation measures based on the level of risk.
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Risk Categories:
‍1.       Customer-Related Risk Suspect Indicators:
These may include inconsistencies in identification documents, fictitious or stolen identities, counterfeit documentation, use of PO box addresses, previous involvement in financial crimes, links to terrorism, individuals with outstanding warrants, lack of valid contact information, and discrepancies in legal entity documents.
Politically Exposed Persons (PEPs):
This category includes individuals holding prominent public positions such as heads of state or government, ministers, members of parliament, members of political party governing bodies, supreme court judges, ambassadors, high-ranking military officials, directors of state-owned enterprises, and directors of international organizations.
‍2.       Country-Related RiskThe Anti-Money Laundering Directive requires enhanced due diligence for business relationships or transactions involving high-risk third countries. This involves obtaining additional information about the customer and beneficial owner, the source of funds and assets, the purpose of the transaction, and securing senior management approval to initiate or continue the relationship.
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This risk-based approach ensures that ILERITER sp. z o.o.effectively manages and mitigates the risks associated with money laundering and terrorist financing.
‍CLASSIFICATION OF CLIENTS BY RISK LEVELLow-Risk Clients:
‍-     Clients residing in a member state of the European Union, a member state of the European Free Trade Association (EFTA), or a party to the European EconomicArea (EEA) Agreement.
-     Clients residing in a third country recognized by reputable sources as having low levels of corruption or other criminal activities.
-     Clients residing in a third country where strong Anti-MoneyLaundering/Counter-Terrorist Financing (AML/CFT) regulations are effectively implemented.
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‍High-Risk Clients:
‍-     Clients whose identity information's authenticity, validity, or integrity is in question.
-     Clients from or located in high-risk third countries.
-     Clients identified as Politically Exposed Persons (PEPs).
-     Transactions that are deemed unusual.
-     Clients exhibiting suspicious behavior that raises concerns about potential misconduct.