1. Scope and objectives

Company EnsoTraffic is committed to preventing money laundering and terrorist financing in its business practices and transactions. Money laundering is the process of concealing the criminal origin of funds. Terrorist financing is any financial support for individuals or organizations that encourage, plan or engage in terrorist activities.

This policy describes the principles and framework applied to internal controls, risk management, monitoring, integrity, and anti-money laundering and anti-terrorism financing procedures.

All employees and contractors involved in the processes described in this document must be familiar with the requirements and responsibilities set out in this policy and comply with them to the extent of their responsibility to ensure the prevention, mitigation and management of risks associated with money laundering, terrorist financing and other criminal activities.
 

2. Definitions

Counterparty - the other party involved in a financial transaction. This may be an individual, business or other organization.
Money laundering - the illegal process of concealing the source of money obtained from criminal activity through complex banking or commercial transactions.
Suspicious transaction - a transaction that is not consistent with the client’s legitimate activities or normal transaction history.
Financing of terrorism — providing financial support to individual terrorists or armed non-state groups.
 

3. Classification of client risks

3.1. Categories of clients
Clients EnsoTrassic are divided into three risk categories:

• Low Risk Clients

• Medium risk clients

• High risk clients

Low risk — clients who pose a minimal risk of money laundering or terrorist financing. Simplified verification may apply.
Medium risk level — standard verification and monitoring procedures are sufficient and applicable.
High level of risk — in-depth verification and approval of business relationships by management is required.

Risk assessment is carried out dynamically, taking into account the data provided at the registration stage and information obtained during interaction with the client.

3.2. Risk factors
The implementation of a risk-based approach includes assessment of the following risk factors:

• type of customer;

• location and geographical origin of the client;

• products, services and transactions;

• channels for providing products and services.

Each risk factor is assigned an appropriate weight depending on its significance.

3.3. Prohibited Clients
The Company does not conduct business with the following persons and organizations:

• persons with signs of possible involvement in criminal activity;

• companies whose legality or source of funds cannot be confirmed;

• whose ownership structure cannot be determined.

The company reserves the right to suspend any transaction that it deems illegal or related to money laundering.
 

4. Commitments

 EnsoTraffic undertakes:

• establish the identity of counterparties;

• check whether counterparties are classified as high risk;

• understand the nature and legality of the activities of counterparties;

• monitor transactions for suspicious activity - if such activity is detected, the counterparty is considered high-risk.

5. High-risk counterparties

 If a counterparty is considered high-risk (for example, included in a sanctions list or commits suspicious actions), the company can:

• terminate cooperation;

• identify beneficiaries and check them against sanctions lists;

• conduct a visit to the counterparty's place of business.

6. Monitoring

The Company continuously monitors customer transactions to identify changes in their risk profile, behavior, transaction volume and other signs of suspicious or fraudulent activity.

The criteria for selecting and identifying marker events, suspicious transactions and customer behavior are reviewed at least once a year.

When a marker event occurs, the system automatically notifies responsible employees. Upon receipt of the notification, the employee reviews the client's data, requests updated information if necessary, and decides to revise the client's risk rating.
 

7. Record storage

All data and documents received within the AML system are stored throughout the entire duration of the relationship with the client and for at least five years after their completion.
 

8. Development and revision

The Legal Department is responsible for developing and implementing this policy and related procedures. EnsoTraffic undertakes to review this policy at least once a year.