Anti-Money Laundering and Counter Terrorist Financing Policy

Introduction

Everest Network Ltd (the Company) and its board of directors is committed to full compliance with all applicable laws and regulations regarding money laundering and the financing of terrorism.
Every officer, director, employee and associated person of the Company is responsible for assisting in the Company’s efforts to detect, deter and prevent money laundering and other activities intended to facilitate the funding of terrorism or criminal activities through its services.

Obligations

The principle requirements, obligations and penalties, on which the Company’s systems and controls are based, derive from the European Union Anti Money Laundering Directives which have been transposed in Malta’s legislation within the Prevention of Money Laundering Act
(Cap.373) (the PMLA) and the Prevention of Money Laundering and Funding of Terrorism Regulations (Cap.373.01) (the PMLFTR). The Company’s obligations also emanate from the Virtual Financial Assets Act (Cap.590) (the VFAA).
The Company has instituted measures in order to:
• comply with rules and regulations regarding customer identification, monitoring and recordkeeping;
• detect and analyse suspicious activity and if required report such activity, and
• develop, update and execute internal policies, procedures and controls.

Apart from the above measures the Company has set up internal procedures concerning the following basic principles:

Sanction lists

National authorities and supranational organizations (such as UN, EU and OFAC) impose restrictive measures against countries, organizations, groups, entities, and individuals. In this respect the Company screens its customers against such sanction lists taking the necessary action should a prospective or current customer be identified.

Risk Assessment

In determining the level of Customer Due Diligence the Company identifies and assesses the ML/TF risk in relation to a customer or particular transaction.
Assessing and understanding client-related money laundering and terrorist financing risks is a critical component of our AFC Risk Management framework, which helps us to mitigate and manage risk in line with our financial crime risk appetite.
The primary objective of risk segmenting our client base is to conduct appropriate due diligence and to ensure a comprehensive client profile is in place to enable the comparison of the results of ongoing monitoring and identify any discrepancies.

Customer On Boarding

The extent and timing in carrying out Customer Due Diligence measures is applied to the customer depending on the outcome of the customer risk assessment. Certainly, the Company, will identify and verify the customer using reliable independent source documents as permitted
by the Regulations.
Verification of the customer’s identification, which will be produced via government-issued documents containing a photographic image, will mainly be carried out utilising video conferencing tools, identity verification software or using recognised commercial electronic data
providers or E-IDs.
In addition to the identity details to be collected and verified, the Company, is also required to verify the wallet address/account number to ensure that the wallet actually belongs to the customer.

Further to the above, the Company, will obtain, in accordance with the Regulations, details as to the purpose and intended nature of the business relationship as well as to determine the customer’s source 
of wealth and source of funds.
In any instance, the Company, will not enter into a business relationship or carry out an occasional transaction unless it has verified the true identity of the customer and its beneficial owners where applicable.

Training

The training of employees plays a vital role in the effectiveness of the Company’s ongoing monitoring systems. We deliver training to help employees understand regulation, compliance, fraud awareness, corruption and sanctions.

Cooperation with Government Bodies

The Company is committed to the fight against money laundering and the financing of terrorism. As such, the Company will cooperate with requests emanating from an authorised Competent Authority as defined within the Regulations.

 

This document is not static and could be amended according to changing regulatory obligations or in accordance with the Company’s risk appetite.