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Anti Money Laundering Policy

GWG (Cyprus) Ltd (hereafter the “Company”) is an Investment Firm incorporated and registered under the laws of the Republic of Cyprus, with registration number C342580. The Company is authorized, and regulated by the Cyprus Securities and Exchange Commission (hereafter the “CySEC”) under the license number 291/16

GWG (Cyprus) Ltd supports the fight for the prevention and suppression of the use of the financial system for the purpose of money laundering and terrorist financing.

GWG (Cyprus) Ltd follows the guidelines set by the Unit for Combating Money Laundering Offences in Cyprus (MOKAS) and has adopted policies and procedures so as to comply with the Prevention and Suppression of Money Laundering Activities Law of 2007, as amended and any directives of its supervisor, the Cyprus Securities and Exchange Commission.

GWG (Cyprus) Ltd has adopted a risk based approach that recognises that the money laundering or terrorist financing threat varies across clients, countries, services and financial instruments, thus enabling the company to differentiate between clients of the company in a way that matches the risk of their particular business.

The risk-based approach adopted by GWG (Cyprus) Ltd involves specific measures and procedures in assessing the most cost effective and appropriate way to identify and manage the money laundering and terrorist financing risks faced by the Company.

Such measures include identifying and assessing the money laundering and terrorist financing risks emanating from particular clients, financial instruments, services, and geographical areas of operation of its clients, managing and mitigating the assessed risks by the application of appropriate and effective measures, procedures and controls and continuous monitoring and improvements in the effective operation of the policies, procedures and controls.

The application of appropriate measures and the nature and extent of the  procedures on a risk-based approach depends on different indicators, such as; the scale and complexity of the services offered, geographical spread of the services and clients, the nature and economic profile of clients as well as of financial instruments and services offered, the distribution channels and the practices of providing services.

GWG (Cyprus) Ltd has put in place systems and procedures according to the provision of the Law and the directive (with the purpose to make sure that its business is not used for the purposes of money laundering or terrorist financing) in relation to the following:

  • customer identification and customer due diligence;
  • record-keeping of customer information;
  • internal reporting of suspicious transactions to the internal anti-money laundering compliance officer and reporting to MOKAS;
  • internal control, risk assessment and risk management in order to prevent money laundering and terrorist financing;
  • detailed examination of each transaction which by its nature may be considered to be particularly vulnerable to be associated with money laundering offences or terrorist financing and in particular complex or unusually large transactions and all other unusual patterns of transactions which have no apparent economic or visible lawful purpose;
  • informing our employees in relation to the Law and the internal policies and anti- money laundering procedures of GWG (Cyprus) Ltd;
  • ongoing training of our employees in the recognition and handling of transactions and activities which may be related to money laundering or terrorist financing.

In the context of the above measures, GWG (Cyprus) Ltd is not to be required (and may be unable under Applicable Regulations) to accept a person as its Client until all documentation it requires has been received by GWG (Cyprus) Ltd, properly and fully completed by such person and all internal GWG (Cyprus) Ltd checks (including without limitation all anti-money laundering customer identification and due diligence checks) have been duly satisfied.

It is further understood that GWG (Cyprus) Ltd reserves the right to impose additional due diligence requirements to accept Clients residing in certain countries where the risk of money laundering may be higher.

During the customer identification and due diligence checks GWG (Cyprus) Ltd shall apply processes to verify your identity as required by the law. GWG (Cyprus) Ltd requires Government issued Photo Identity documents such as either a passport, and / or Identity Card containing your full name, personal photo, and date of birth, ID number and expiry date as well as evidence of your residential address, such as a utility bill or bank statement, that was issued in the last 3 months for the verification process. The information in these documents must correspond with the details submitted in your application. Furthermore, in certain circumstances we may require this information to be authenticated by an appropriate third party.

In addition, GWG (Cyprus) Ltd does not accept cash, money orders, third party transactions, exchange houses transfers or Western Union transfers or similar prepaid vouchers / cards i.e PaySafe etc. GWG (Cyprus) Ltd will reject any deposits from accounts not belonging to the client or effect any withdrawals to third parties. All

withdrawals will be allowed to be made using the same method originally used to credit the client’s account i.e. withdrawal will only be allowed to be made to the credit card that was used to credit the account.

Trading accounts are one vehicle that can be used to launder illicit funds or to hide the true owner of the funds. In particular, a trading account can be used to execute financial transactions that help obscure the origins of the funds. GWG (Cyprus) Ltd direct funds withdrawals back to the original source of remittance, as a preventative measure.

International anti-money Laundering requires financial services institutions to be aware of potential money laundering abuses that could occur in a customer account and implement a compliance program to deter, detect and report potential suspicious activity.

These guidelines have been implemented to protect GWG (Cyprus) Ltd and its clients. For questions/comments regarding these guidelines, contact GWG (Cyprus) Ltd Compliance Department at [email protected]

CLIENT ACCEPTANCE POLICY

The Client Acceptance Policy defines the criteria for accepting new clients and defines the client categorisation criteria which shall be followed by the company and especially by the employees which shall be involved in the client account opening process. GWG (Cyprus) Ltd shall classify clients into various risk categories and based on the risk perception decide on the acceptance criteria for each category of client.

CLIENT DUE DILIGENCE AND IDENTIFICATION PROCEDURES

GWG (Cyprus) Ltd will apply client identification procedures and client due diligence measures.

ON-GOING MONITORING PROCESS

The constant monitoring of the clients' accounts and transactions is an imperative element in the effective controlling of the risk of money laundering and terrorist financing.

RECOGNITION AND REPORTING OF SUSPICIOUS TRANSACTIONS / ACTIVITIES

All cases where there is an attempt of executing transactions that that are related to money laundering or terrorist financing, GWG (Cyprus) Ltd will proceed in accordance with the Law.

Download Anti Money Laundering Policy